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Payment Apps May Trigger Bank Act

Daily Journal
10/15/14

Nossaman Partner 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 Mr. Richard, 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.

For more information on this article, please contact the author.

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