Banking
Oct. 16, 2014
Payment apps may trigger bank act
Are mobile payment apps subject to the enforcement penalties of the Bank Secrecy Act? The broad definition of "financial institution" and recent developments suggest real enforcement risk for the unwary. By Patrick Richard
Are mobile payment apps, such as Google Wallet and Apple Pay, subject to the enforcement penalties of the Bank Secrecy Act (BSA)? The broad definition of "financial institution" under the act and recent developments suggest real enforcement risk for the unwary. Are these applications simply payment processing companies (which would not be subject to the BSA), or should they be considered money service businesses (which would be subjec...
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