4 see the merchant processing booklet of the comptroller s handbook pp.
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.
Global companies should incorporate aml risks into their risk analysis of their third party distributors agents and other intermediaries.
Third party payment processors often use their commercial bank accounts to conduct payment processing for their merchant clients.
And occ bulletin 2006 39 pp.
31 2017 23t for purchase volume worldwide on general purpose cards from american express discover diners club jcb mastercard unionpay and visa.
Anti money laundering and third party payment processors tppps marcia francis 4 note.
The basic questionnaire due diligence risk analysis contractual provisions training and partner code of conduct should reflect attention to this risk.
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.
The ffiec s bank secrecy act anti money laundering examination manual third party payment processors.
Nilson report as of dec.
3 see the merchant processing booklet of the comptroller s handbook pp.