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Table of Contents

Lead Story

Loyalty, the currency of choice

Ann Train


Industry Update

Disputes rekindled by Financial CHOICE Act

Barcode technology gets digital makeover

Home Depot joins chip-and-PIN protest

Aussie crackdown on card surcharges


FICO pedestal cracking

Acquirer Earnings Roundup: May 2016

Mobile coupon tidal wave

Restaurant patronage on the rise


CFPB targets payday lenders: What's next?

Patti Murphy
ProScribes Inc.

Brexit doesn't mean UK will exit fintech race

David Poole

Will vaping go up in smoke?

Brett Husak
National Bank Services


Street SmartsSM:
Shifting MLS strategies and models

John Tucker
1st Capital Loans LLC

Taking stock at mid-year 2016

Jeff Fortney
Clearent LLC

Five ways to combat attrition effectively

Aaron Nasseh
Finical Inc.

Guide to a successful portfolio acquisition strategy

Adam Hark

Company Profile

Traffic Jamming

New Products

Simple, secure cross-border payments

UP eCommerce Payment Solution
ACI Worldwide Inc.

360-degree solution for chargebacks issues

Chargeback Gurus


Finding opportunity


Letter from the editors

Readers Speak

Resource Guide


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The Green Sheet Online Edition

July 11, 2016  •  Issue 16:07:01

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Readers Speak

SAR obligations for transaction laundering

Given the ongoing government actions against payment companies accused of knowingly processing fraudulent transactions, we thought readers of The Green Sheet would be interested in our most recent blog post. Here's an excerpt:

Suspicious Activity Reporting (SAR) forms the cornerstone of the Bank Secrecy Act (BSA) reporting system. Broadly speaking, federal regulations require all banks and financial institutions to file a SAR with respect to a host of financial crimes and transactions conducted or attempted through them if they know, suspect or have reason to suspect that the transaction may involve potential money laundering or other illegal activity. FinCEN regards credit card laundering and factoring as a variation of money laundering, equally subject to SAR requirements.

Credit card laundering occurs when a merchant uses a straw entity to act as a front, pass-through or aggregator for the merchant's transactions. Other indicia include multiple MIDs, multiple corporations and a continuity negative option model. Almost always, such conduct violates federal civil law, such as Section 5 of the Federal Trade Commission Act and the Telemarketing Sales Rule, as well as federal criminal law, such as 18 U.S.C. § 1029 (factoring), 18 U.S.C. § 371 or § 1029(b)(2) (conspiracy), 18 U.S.C. § 1343 (wire fraud), or 18 U.S.C. § 1344 (bank fraud). Many states also have their own laws against transaction laundering.

Yet except for certain money services businesses (MSBs), nonbank third-party organizations such as ISOs/MSPs, payment facilitators/payment service providers, data processors and network providers (collectively TPOs) generally are not subject to BSA requirements. Thus, it is the acquiring bank's responsibility to (1) ensure that a TPO's incident reporting and management program contains clearly documented processes and accountability for identifying, reporting, investigating, and escalating incidents of credit card laundering and other suspicious activity; and (2) monitor TPO compliance and processing information on an ongoing basis to ensure compliance with the acquirer's SAR obligations.

Theodore F. Monroe and Bradley O. Cebeci,TFM, The Payments Law Firm

What do you have to offer?

Do you know of resources of have knowledge that would be helpful to your colleagues in payments? We'll be happy to help spread the word right here. Email us at

Notice to readers: These are archived articles. Contact names or information may be out of date. We regret any inconvenience.

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