February 17, 2017
Suspicious Activity Reporting (“SAR”) forms the cornerstone of the Bank Secrecy Act (“BSA”) reporting system. Broadly speaking, federal regulations require all banks and financial institutions to […]
February 16, 2017
This is the third of four articles that will use the case to examine card-not-present fraud from a legal perspective. Part 1 described the case and […]
February 15, 2017
Recently, the criminal case against online merchant Jeremy Johnson in Utah that started back in June 2011 finally came to a close. After more than four […]
February 14, 2017
Late last month, the criminal case against Jeremy Johnson that started back in June 2011 finally came to a close. After more than four years of […]
February 13, 2017
Payment companies get sued. It is a normal course of business. They plan for it and they are willing to pay for it. The truth is, […]
February 12, 2017
In November 2015, the Federal Trade Commission (“FTC”) reported its spearheading of a nationwide crackdown (known as Operation Collection Protection) along with more than 70 federal […]
February 10, 2017
Department of Justice introduced Operation Choke Point in early 2013 as an enforcement initiative to choke off swindlers’ access to the payments system by targeting the […]
February 9, 2017
Little more than a year ago, the United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued written guidance to banks for extending merchant services to […]
February 8, 2017
The day has finally arrived: The federal government has decided to make payment processors and ISOs completely (and ridiculously) responsible for the “sins” of their merchants. […]