Page 31 - GS230301

Education

It's important to maintain confidentiality around the Agents, ISOs, acquirers, payment facilitators and others
sensitive information collected for OFAC screening are all in the business of collecting identifying information
to protect well-meaning customers and to ensure the of merchant account applicants precisely so that they can
integrity of the acquirer's anti-money laundering (AML) be vetted against OFAC lists.
processes.
Know-your-customer processes are important not simply
How do ISOs, processors and acquirers for sanction screening purposes, but also for making sure
participate in sanctions compliance? that the new MID is controlled by only the rightful owner
of the MID. When the representative of a merchant tries,
A payment processing account issued by an acquiring for example, to change the direct deposit account on a
bank or payment facilitator, often synonymous with the MID, having a fix on the identity of the true owner for
term "merchant identification number" or MID, is actually verification purposes could be helpful.
akin to a bank account. It is like a bank account because
it accumulates and holds merchant funds that are then In essence, everyone doing business in the merchant
settled to the merchant either daily or on some other acquiring value chain must be part of the solution. This
schedule. As with any financial account in the United sounds a bit like a PSA, but all participants in the payments
States—even a Venmo or Dwolla account—the provider of industry are partners in the fight against financial crime.
the account must ensure that the account-holder is not on
a sanctions list (an SDN).

To verify whether a person is an SDN, they must be In publishing The Green Sheet, neither the author nor the publisher
identified, and their identifying information must be isengaged in rendering legal, accounting or other professional services.
compared to the OFAC SDN lists. Where the applicant for If legal advice or other expert assistance is required, the services of a
a merchant account is a company—which is the case most competent professional should be sought. For further information on
of the time—owners of 25 percent or more of the applicant this article, please contact Adam Atlas, attorney at law, by email at
company must be vetted against OFAC lists. atlas@adamatlas.com or by phone at 514-842-0886.

We Buy Agent Portfolios

David Daily
Zach Daily CEO & Founder Alex Daily
Business Development Business Development
Denise Shomo Katelyn Schickling
President Business Development
Contact us today for a complementary portfolio valuation

or to inquire about our referral program for ISOs

+1.610.451.4096
cutterfinancial.com

31