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Experience Connections Knowledge

July 8, 2022 | Aisha Hall

Third-Party Senders: Are you a Money Transmitter?

      As a corporation that handles ACH transactions on behalf of others, you may have heard your financial institution refer to you as a “Third-Party Sender.” Common examples of Third-Party Senders include payroll processing companies, rent payment companies, and other bill pay providers. If an entity is designated as a Third-Party Sender, it …

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January 21, 2021 | Nicole Meisner

New Joint Regulatory FAQs Regarding Suspicious Activity Reporting and other AML Considerations

On January 19, 2021, several federal banking regulators including FinCEN, the Federal Reserve, the FDIC, NCUA, and the OCC jointly issued answers to several frequently asked questions (FAQs) regarding suspicious activity reports (SARs) and other anti-money laundering (AML) considerations for financial institutions covered by SAR rules.  As used below, the term “financial institution” includes money …

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April 28, 2020

COVID-19 and Payment Processing Contracts

A variety of important provisions in contracts for payment services are being significantly impacted by COVID-19. If you are concerned about a party’s ability to meet the obligations of an agreement – your own or the other side’s — it is important to evaluate those terms and conditions carefully to determine if and how the …

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February 7, 2020 | Jaffe Law

California Consumer Privacy Act (CCPA) Goes into Effect

As of January 1, 2020, the California Consumer Privacy Act (CCPA) is now in effect. As we explained here, the CCPA imposes requirements on merchants and payment processors to protect personal information of California residents. Enforcement of the law does not begin until July 1, 2020, which is good because the regulations interpreting the law …

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