For years, “FBO” has been one the payments industry’s favorite buzz words. The FBO account structure has been a common “best practice” by payments providers seeking to remove themselves from the flow of funds to reduce their risk of being regulated as a money transmitter. As a foundational matter, FBO accounts are merely custodial depository accounts maintained at financial institutions and established “for the benefit of” (FBO) intended beneficiaries of funds in the accounts. The structures of such accounts can
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