AML/CFT Risk: Third-Party Payment Processors

In our AML/CFT Membership Group, Kevin discussed the risks posed by third-party payment processors (TPPPs). TPPPS are entities that transmit funds between customers and merchants without directly handling goods or services. They might include ACH originators, prepaid card program managers, mobile wallet platforms, payment gateways, remotely created checks, etc., and are common in certain spaces like FinTech, E-commerce, gambling or gaming platforms, adult entertainment, crypto exchanges, telemarketers, etc.

The FFIEC devotes an entire section to TPPPs in its BSA/AML Manual outlining the risks and examiner expectations.

In the video, Kevin touches on the types of TPPPs financial institutions might encounter:


Published
2025/09/10

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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