The Financial Action Task Force (“FATF”) recently released a white paper entitled “Guidance for a Risk Based-Approach: Prepaid Cards, Mobile Payments and Internet-based Payment Services” (“Guidance”). The Guidance contains nonbinding suggestions for policy makers on ways to improve their respective country’s money laundering controls by applying existing FATF Recommendations to new and emerging financial services providers. Because the FATF is an inter-governmental body and the United States is an active member, the Guidance has important implications for nonbanks and service providers that are expanding into the mobile payments space, especially those who are offering products that do not neatly fit within the existing Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) requirements set forth by the Financial Crimes Enforcement Network (“FinCEN”) and other federal offices such as the Office of Foreign Assets Control (“OFAC”).
OVERVIEW OF THE GUIDANCE -
The Guidance is meant to explain how the risk-based AML principles in the existing FATF Recommendations can be applied to each of these three payment types. The document consists of seven sections, which can be summarized as follows...
Please see full alert below for more information.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.
Topics: Anti-Money Laundering, Financial Action Task Force, Mobile Payments, Risk Assessment, Risk Management, Telecommunications
Published In: Communications & Media Updates, Finance & Banking Updates, International Trade Updates, Science, Computers & Technology Updates
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
© Morrison & Foerster LLP | Attorney Advertising