In the payments world, commentators note Illinois’ recent Interchange Fee Prohibition Act, which prohibits charging interchange fees on the tax or tip portions of processed transactions.

Key portions of the law take effect July 1.

By its terms, the Interchange Fee Prohibition Act also contains a general privacy rule restricting the use of payments transactional data:

(b) An entity, other than the merchant, involved in facilitating or processing an electronic payment transaction, including, but not limited to, an issuer

Continue Reading Payments and Privacy – What Issues Should Payment Service Providers Be Paying Attention To?

On January 19, 2021, several federal banking regulators including FinCEN, the Federal Reserve, the FDIC, NCUA, and the OCC jointly issued answers to several frequently asked questions (FAQs) regarding suspicious activity reports (SARs) and other anti-money laundering (AML) considerations for financial institutions covered by SAR rules.  As used below, the term “financial institution” includes money services businesses.

Importantly, the FAQs do not alter existing BSA/AML legal or regulatory requirements, nor do they establish new supervisory expectations.  Instead, they are intended to clarify the regulatory requirements related to SARs to assist financial institutions with their compliance obligations.
Continue Reading New Joint Regulatory FAQs Regarding Suspicious Activity Reporting and other AML Considerations