Payment Apps May Trigger Bank Act

10.15.2014
Daily Journal

Patrick Richard authored the front page Daily Journal article, "Payment Apps May Trigger Bank Act" regarding mobile payment apps' subjection to enforcement penalties brought on by the Bank Secrecy Act (BSA).

According to Patrick, the broad usage of the term "financial institutions" in the BSA suggests a real enforcement risk for companies behind mobile payment processing applications, such as Google Wallet and ApplePay . The enforcment of these penalties depends on whether the app is considered a money service business which, in that case, would make it subject to BSA.

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