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FinTech: The Emerging Financial Crime Compliance Minefield

By Daniel R. Alonso and Timothy Stone

More than ever, the intersection of technology and financial crime compliance (FCC) for financial institutions is dynamic terrain. At the same time, technology continues to improve, and sometimes disrupt the way in which consumers and businesses participate in the financial services industry. The proliferation of so-called “FinTech” ' particularly by startups outside the financial sector ' raises a host of thorny FCC issues for regulators and financial institutions required to comply with the Bank Secrecy Act (BSA) and its anti-money laundering (AML) mandates. These include how to define the financial crime risks at play; if, how, and to what extent a new technology or service falls within the scope of existing regulations; and, for banks and other institutions that partner with FinTech startups, ensuring compliance with rules on third-party risk.

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