Compliance in the Peer-to-Peer Payment Landscape

Financial Services attorneys Andres Fernandez, Gabriel Caballero and Kristen Jimenez co-authored a Daily Business Review article discussing the compliance challenges faced by financial institutions in the rapidly evolving peer-to-peer payment landscape. The article explores how the rise of instant payment platforms such as Venmo and Zelle has introduced significant complexities for banks, particularly international institutions, in adhering to anti-money laundering (AML) and economic sanctions regulations. The authors highlight the difficulties in implementing effective compliance measures as a result of the real-time nature of these transactions and the limited user information available. They also highlight increased regulatory scrutiny and recent enforcement actions, urging financial institutions to adopt risk-based approaches and regularly update their compliance controls to address the unique challenges posed by modern payment systems.

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