Third Party Payment Processors Aml

3 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.
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 basic questionnaire due diligence risk analysis contractual provisions training and partner code of conduct should reflect attention to this risk. Nilson report as of dec. To the extent that global companies rely on a network of third party distributors and sub distributors.
Anti money laundering and third party payment processors tppps marcia francis 4 note. Third party payment processors overview ffiec bsa aml examination manual 235 2 27 2015 v2 third party payment processors overview objective. 4 see the merchant processing booklet of the comptroller s handbook pp.