Banks are required to implement risk-based OFAC Compliance Programs designed to identify Sanctioned Entities and block access to funds that are in the bank's possession. Seems simple, but it gets very complicated when the Bank allows payment processors to settle payments for others to the Processors account at the bank. In these circumstances, the bank relies upon the Payment Processor to identify their customers (including Beneficial Owners) and to screen these parties against Sanctions lists. Not so simple but manageable. But YIKES, what about Nested-Payment Processors? Now we have a bank's customers, customers, customer (and Beneficial Owners) to consider.
In this session the TPPPA will discuss the importance of implementing risk-based OFAC Compliance Management Programs in Third-Party Payment Processing, including Risk Assessment, Policies, Procedures, and other internal controls.
Speaker: Marsha Jones, President of the TPPPA
CEUs: Up to 1.2 AAP & APRP Available for this Session
Sponsored by: Third Party Payment Processors Association (TPPPA)