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Education



                                                                                             So,  fintech  startups  and
                                                                                             other  payment  compa-
                                    Legal ease:                                              nies stumbled across just-
                                                                                             in-time card issuing to
                                                                                             get money  out the door
                                                                                             and into the hands of in-
        Issuing: the new acquiring                                                           tended payees. Since, in
                                                                                             the United States, issu-
                                                                                             ers are all banks, the is-
        By Adam Atlas                                                                        sue of money transmitter
        Attorney at Law                                                                      licenses is  often (but not
                                                                                             always) quelled. For "af-
              ssuing is the new acquiring. Formerly, card issuing strictly involved printing physical   filiate payout" providers
              cards and sending them by special delivery to cardholders, who would then call their   and business "supplier
              issuers to activate their cards, then start spending via card-present transactions. That   payments,"  VAN  issuing
        I was your dad's issuing business. Today's issuing involves issuing thousands of sin-  is a convenient way to
        gle-use prepaid debit or even credit cards, also known as virtual account numbers (VANs)   facilitate outdoing pay-
        that fly around the world in seconds to be "presented" at acquirers who might also be cre-  ments. A combination of
        ating payfac sub-merchant accounts in similar quantities to help accept them. This article   the cost of money trans-
        highlights issues related to the torrent of issuing occurring now – without out knowledge.  mitter licensing and the
                                                                                             ease of distributing VANs
        What is a VAN?
                                                                                             How does it work?
        A VAN, or virtual account number, comprises the same 16 digits we are used to seeing on
        credit and debit cards and, but for the lack of a physical card, performs the same function   Banks operate  issuing
        as a physical payment card. A VAN has an issuer and authorizations and card balances that   programs  using  a  pro-
        enable the cardholder to spend with the VAN. A virtual card can be uploaded to a phone   gram manager that is es-
        wallet and enable NFC payments from the phone.                                       sentially an ISO, but for
                                                                                             card issuing instead of
        Why rush on issuing?                                                                 acquiring. The program
                                                                                             manager is like a "whole-
        Issuing is the poor man's money transmission. For a payments company to send value from   sale ISO" and takes charge
        Person A to Person B, a payment company normally requires money transmitter licens-  of finding cardholders,
        es from each state and a registration with the U.S. Department of the Treasury Financial   hiring a processor to
        Crimes Enforcement Netork (FinCEN). That process takes a long time and costs about $2   handle card issuing data,
        million.                                                                             ensuring that cards are
                                                                                             funded, monitoring card
                                                                                             load transactions for AML
                                                                                             and  other suspicious  ac-
                                                                                             tivity and overseeing the
                                                                          /USAePay           compliance  and  security
                                                                          /USAePay
                                                                                             of the program. Issuing
                                                                                             banks do surprisingly lit-
                                                                                             tle. The program manag-
                                SMARTER SOLUTIONS                                            ers guarantee to the issu-
                                                                                             ing banks that cards will
                              FOR SECURE PAYMENTS                                            be funded and provide
                                                                                             first-line customer sup-
                                                                                             port to cardholders.
                                            Ecommerce
                                                                                             Any AML concerns?
                         Retail
                                                                                             Given that VANs are is-
                                                                                             sued by the thousands and
                                 WELCOME
                                                                                             can be used anywhere in
                                                                                             the world in seconds, they
                                                                  Mobile
                                                                                             engender AML concerns.
                                                                                             The program manager,
                                                                                             under the supervision of
              www.USAePay.com                                          866.490.0042
                                                                                             the bank, is charged with
                                                                                             overseeing issuing pro-

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