The House Financial Services Committee Letters
US House Financial Services Committee leaders demand agencies disavow Operation Choke Point, protecting bank account access for MTOs and MSBs.
Money Transfer Business Is on the Rise — Time to Get Out… Or time to get in?
Explore why US banks are walking away from the rising remittance market due to strict compliance, while new fintech solutions disrupt the landscape.
DE-RISKING: THE MOVING TARGET
De-risking is a moving target. Hugo explores how massive bank account closures hit legitimate MTO networks, sparking a critical remittance crisis across high-risk global regions.
DEVELOPING PARTNERSHIPS WITH US LICENSED MONEY TRANSMITTERS
How can fintech startups navigate complex US licensing? Judie Rinearson explains how partnerships with licensed money transmitters boost innovation.
US TREASURY ROUNDTABLE ON FINANCIAL ACCESS FOR MONEY SERVICE BUSINESSES
Right at 9 am, in the Cash Room of the Treasury Building last Tuesday, January 13th,, 100+ attendees gathered to participate in the Roundtable.
FINCEN Director’s Remarks 8/12/2014
FinCEN Director Jennifer Shasky Calvery addresses de-risking, urging banks to manage MSB risk rather than shutting legitimate businesses out.
Cross Border Currency Exchange: The US-Mexico Border
Explore how rising bulk cash smuggling fears and strict compliance rules force legitimate exchange firms out of business along the US-Mexico border.
The Compliance Profession after the US 5 Million Thomas Haider proposed fine
FinCEN’s fine against Thomas Haider signals a shift to individual liability, changing the risk landscape for compliance officers in the MSB industry.
Customer Expectations In The Payments Industry
Industry In attempting to determine future trends in the payments industry, a good question to ask is, “What are customer expectations?”. I believe we can all agree that customers want the payments they send and receive to be realized in real-time with minimum fees. They also want the option of which payment service provider they choose to…
A new decade for us
Coinciding with the celebration of the 10 year anniversary of IMTC conferences we are faced with one of the most exciting and challenging organizational shifts: The Platinum Network (PNET). Bringing these conferences to life over the past 10 years implied a lot of work in the sense that it took time, energy, and creativity and…
laBITconf 2019 in its 7th Edition
LaBITconf, the Latin American Bitcoin and Blockchain conference is probably one of the conferences that I enjoy the most every year. And this time, in its 7th edition in Montevideo, Dec 12-14, it was quite an event again. LaBITconf is so full of life, creativity, originality, where you can feel the desire for change, a…
Risk Management in US MSB Institutions
Introduction The US Bank Secrecy Act (“BSA”) requires that every Money Services Businesses (“MSB”) implement a BSA/Anti-Money Laundering (“AML”) Compliance Program. Risk assessments provide a clear view as to the organization’s policies and procedures. Failure to implement a comprehensive BSA/AML Compliance Program may result in significant fines and/or penalties by state and federal regulators. So,…
Digital vs. Cash, are we getting it all wrong?
This article was conceived after discussing with colleagues in the industry why the payments world has been driven into the Cash vs. Digital dichotomy. My research on cash has been inspired by analyzing the penalization of cash-based industries, such as the money transfer industry by the banking sector, which has resulted in the derisking phenomenon…
The Antimonopoly Prosecutor in Chile sides with MSBs on Bank Account Closures
We thank our colleague Carlos Grossman, for the report out of Chile where the Antimonopoly Division of the National Economic Prosecutor Office (División Antimonopolios de la Fiscalía Nacional Económica – FNE) reports the investigation that took place after an August 2015 complaint by a Forex Firm denouncing seven banks of denying the opening of a…
Identity Matching in the Money Transfer & Payments Industry
I am going to venture myself to write this article on Compliance, with the disclaimer that I am not a compliance professional and that the idea behind this is to get compliance colleagues to comment and compliance officers to pay attention. Talking last week to a fintech company about their payment processing services in Mexico,…
Blockchain-based solutions to the Caribbean derisking problem
De-risking was an acute illness for the Caribbean financial sector in 2015 and 2016. In 2017, the height of the fever has broken, but the patient is still sick. Though correspondent banks in developed countries are no longer dropping services to Caribbean banks at a rapid pace, the region’s economies remain encumbered with a residue…
DE-RISKING: THE RISK OF NO RISK
Daniel Trías, consultant and specialist in foreign trade, banking, finance and family remittances, founder of DT Consulting and Member of the IMTC Advisory Board and who has accompanied the “Cono Sur” (southern cone) Associations in their meetings, their initiatives to find solutions to De-Risking, such as Creation of CIASEFIM, presents this Document entitled: “De-Risking: The…
DE-RISKING AND THE GREAT UNBANKING CHALLENGE
How De-Risking is changing the face of Financial Services worldwide In July 6th & 8th the Economist published two articles that, again, raised the de-risking threat discussion to new levels. The July 6th article was entitled “The great unbanking [1] – Swingeing fines have made banks too risk-averse – It is time to rethink anti-money-laundering…
The Taxing of Remittances in the US
Update – February 16, 2018 ; New Bill in Oklahoma and Nebraska – Contributed by the MSBA Georgia & Iowa move to leverage a tax on remittances – Financial Institutions are reacting In a previous blog (in Spanish), posted in the midst of the many reporter calls, especially from Latinamerica (driven by the anxiety over the…
The shifting views on family remittances
After a series of media interviews a couple of weeks ago, in a trip to Guatemala, I realized in a moment that I was witnessing a change in the public perception of remittances that I had not grasped before. Answering one by one journalist questions, it was unquestionable that I was witnessing a shift that I had not noticed before. After thinking about it, I could say that the shift is global although that doesn’t mean that a shift is happening in the same way or at the same time in every region or country in the world. Having been a part of the remittance industry for three decades I suddenly saw it very clearly. But I don’t want to get ahead of myself so let’s back up a little.
Las amenazas de Trump – Remesas, impuestos, migración, deportaciones y la construcción del muro
Remesas, impuestos, migración, deportaciones y la construcción del muro
Durante las primarias presidenciales republicanas del año pasado, Donald Trump expuso su propuesta de cómo forzar a México a pagar por el muro de 1,000 millas en la frontera entre Estados Unidos y este país. Los periodistas Bob Woodward y Robert Costa del Washington Post publicaron en Abril 5 de 2016 la noticia (http://wapo.st/2jbWHFn) en la cual Trump manifestaba su intención de amenazar a México con “cortar el suministro de remesas”. Trump envió en esta ocasión un memorando de dos páginas…
Michael McDonald, in memoriam
Michael was a 27-year veteran of the Internal Revenue Service, Criminal Investigation Division. He retired in 1998 and formed a Miami based consulting firm specializing in international money laundering, Bank Secrecy Act, Patriot Act, asset forfeiture, compliance and related matters. The firm has been a network of retired Special Agents, each with in-depth experience in money laundering investigations.
The US CSBS & the MTRA Report on the State of MSBs Regulation & Supervision
The Conference of State Bank Supervisors (CSBS) and the Money Transmitter Regulators Association (MTRA) released an important report on the state of the industry that is a must read for anyone in the industry and a report that all US Money Transmitters should be sending to their banks. The report is entitled “The state of state money services businesses regulation & supervision” and it examines the non-bank financial sector in the US and the bank discontinuance and de-risking challenges the industry faces. But the main objective is to let the banks know of the strict regulations and close supervision the state regulators have on all licensed MSBs.
MONEY TRANSFER COMPANIES WIN A MATCH AGAINST BANKS IN BRUSSELS
The Spanish Courts petitioned the European Tribunal for a guidance to clarify Bank Account Closure Cases and the presumption of remittances being high risk
Our IMTC speaker and colleague Antonio Selas from the firm Cremades & Calvo Sotelo in Madrid has been preventing Banks from closing bank accounts of MTOs in Spain by taking to court the banks and convincing judges that Banks are discriminating against their competitors and that their “remittances are high risk” argument has no factual evidence. We met Antonio Selas in IMTC EMEA 2015 in Istanbul and he came to Miami and made a presentation in IMTC WORLD 2015 entitled “Bank Account Closures Are Against the Law“.
FATF-GAFI GUIDANCE – A Risk-Based Approach for Money or Value Transfer Services
The timing could not have been better. FATF just published – February 2016, a report that all Compliance Officers of this industry must read, entitled Guidance for a Risk-Based Approach for Money or Value Transfer Services (Summary – Full Report (69 pages). I want to highlight three statements in the presentation of the report:
- The risk-based approach, the cornerstone of the FATF Standards, requires that measures to combat ML/TF are commensurate with the risks. Such measures should not necessarily result into the categorization of all MVTS providers as inherently high-risk.
- The overall risks and threats are influenced by the extent and quality of regulatory and supervisory framework, as well as the implementation of risk-based controls and mitigating measures by each MVTS provider.
- While this Guidance is applicable to the entire MTVS sector (both banking and non-banking institutions offering MVTS); it is primarily intended for non-banking MVTS providers.
GAO Reports on International Remittances
I think it is very important that every person in this industry reads the GAO Report published on February 16th, 2016, entitled INTERNATIONAL REMITTANCES: Actions Needed to Address Unreliable Official U.S. Estimate – Highlights Page (1 page), Full Report (62 pages). A second report published the same day is entitled INTERNATIONAL REMITTANCES: Money Laundering Risks and Views on Enhanced Customer Verification and Record keeping Requirements– Highlights Page (1 page), Full Report (59 pages), Accessible Version (62 pages).
