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Education

national security considerations and not on the race or re- Today, common sense often involves incorporating screen-
ligion of the countries singled out for sanctions. ing services into client underwriting and monitoring that
are powerful complements to human oversight.
Common sense
Training
Payments businesses are often offered lucrative oppor-
tunities of dubious provenance. When a merchant has Each person in a payments business should benefit from
an enormous volume of processing but no corresponding training that fits his or her specific function. Training is
marketing, sales or operational substance, a provider is especially important in KYC/AML roles where specific
right to ask questions about the basis of the high volume skills are required to comply with the law and protect
of payments. This is common sense and practiced by most payments businesses from abuse. Without the right
payments providers that I have advised. training; policies, procedures and screening services are
not much use, and can even be harmful to the business.
Newer providers are particularly vulnerable to abuse by
criminals. Startups have three strikes against them that Typically, the point of failure of payments in national
make them vulnerable to abuse. First, they are up against security is found only after the fact. That's why payments
the high cost of starting a new business. Second, they do providers should implement best practices throughout
not yet have revenue, which would otherwise allow them their operations to catch failures before they happen.
to be more selective in choosing clients. Finally, early
startups are sometimes naïve as to the illicit purpose of In publishing The Green Sheet, neither the author nor the publisher is
certain potential clients.
engaged in rendering legal, accounting or other professional services.
These three factors come together requiring investors, If legal advice or other expert assistance is required, the services of a
suppliers and advisors to startups to reduce the risk of competent professional should be sought. For further information on
abuse of their services by exercising mature decisions this article, please contact Adam Atlas, attorney at law by email at
about client selection and oversight – despite temptations atlas@adamatlas.com or by phone at 514-842-0886.
otherwise.

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