Third Party Payment Processors Aml

For example the processor may deposit into its account rccs generated on behalf of a merchant client or process ach transactions on behalf of a merchant client. To the extent that global companies rely on a network of third party distributors and sub distributors. Third party payment processors job aid this job aid is to be used by state institution examiners as a means to understand identify and assess the risks associated with institutions relationships with a common type of third party service provider third party payment processors or senders herein referred to as tppps or processor s.

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Third party payment processors aml.

Assess the adequacy of the bank s systems to manage the risks associated with its relationships with third party payment processors and management s ability to implement. 3 see the merchant processing booklet of the comptroller s handbook pp. Anti money laundering and third party payment processors tppps marcia francis 4 note. 31 2017 23t for purchase volume worldwide on general purpose cards from american express discover diners club jcb mastercard unionpay and visa.

4 see the merchant processing booklet of the comptroller s handbook pp. Third party payment processors overview ffiec bsa aml examination manual 235 2 27 2015 v2 third party payment processors overview objective. Global companies should incorporate aml risks into their risk analysis of their third party distributors agents and other intermediaries. And occ bulletin 2006 39 pp.

Third party payment processors often use their commercial bank accounts to conduct payment processing for their merchant clients. Nilson report as of dec. The basic questionnaire due diligence risk analysis contractual provisions training and partner code of conduct should reflect attention to this risk.

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