Fincen, Payroll and Third-Party Sender

The Role Of Reputation In Managing Risk

PYMNTS

OCTOBER 13, 2017

A bank using a payments processor for payroll may be “on the hook” for that processor’s customers. As an example, Hennessy noted the recent debut of NACHA’s third-party sender rule, which took effect at the end of September. This is not to say that KYC becomes KYCC with 18 CCCs down the line.

Risk

Risk Consumer Financial Protection Bureau (CFPB) Due Diligence Third-Party Sender

Payments Space

The Role Of Reputation In Managing Risk

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