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January 26, 2016
It is no secret that banks struggle to effectively serve small businesses. Internal battles to serve these clients have existed within financial institutions for quite a while: battles between commercial banking teams claiming to offer more of the functionality these customers need and the consumer teams promising greater solution ease of use. Unfortunately, in recent years, the size of the...
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January 19, 2016
The FinCEN guidance provides substantial clarification around filing SARs and CTRs for marijuana-based businesses. In essence, the guidance states institutions should file SARs and CTRs as if the customer is an illegal business, though not necessarily terminate the account. This could easily cause some confusion, since this deviates from the normal practices; in most cases, an entity known to be...
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Ben Knieff
January 14, 2016
Transaction monitoring Most organizations have rather mature and effective transaction monitoring systems in place, but they may not be ready for these new types of businesses and their transaction patterns. For example, with a marijuana dispensary or retailer, many of their customers choose to pay in cash, which will result in large daily cash deposits (more on this later). Transaction...
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Ben Knieff
January 12, 2016
In a previous post we looked at some of the challenges posed by the interplay between state and federal laws and the guidance that impacts how banks could service marijuana business that are legal at the state level but not at the federal level. Both the New York Times and the BBC have published pieces about these businesses’ challenges in obtaining banking services because financial institutions...
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Ben Knieff
January 11, 2016
We are only several days into the new year and life insurance executives everywhere are scurrying to figure out how to meet their 2016 goals (or catch up on any 2015 goals). As life insurance companies shift their focus to the customer—the policyholder/prospect and not the agent—improving underwriting has been front and center. Surprisingly, though, many insurers remain unaware of the full extent...
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Samantha Chow
January 5, 2016
As we ring in 2016, the new year promises to be an active year for financial institution (FI) fraud executives. We’re still in the thick of the U.S. migration to EMV, and many FIs are still scrambling to get their cards out the door. FIs that are ahead of the game are already reaping the results—one executive who I interviewed from a large FI said its migration is 90% complete, and it already saw...
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January 5, 2016
The Financial Crimes Enforcement Network (FinCEN) and U.S. Department of Justice (DOJ) released guidance for financial institutions on servicing marijuana-related businesses in early 2015. While no doubt appreciated by the banking community, it may not make financial institutions more confident in servicing these businesses. The New York Times did a nice article on the guidance, explaining what...
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Ben Knieff
December 15, 2015
In the machine-to-machine scenario, the blockchain remains completely transparent to “human” business users, and it will be deployed to develop solutions tied to the Internet of Things. The IoT is the network of physical objects or "things" embedded with electronics, software, sensors, and network connectivity, which enable these objects to collect and exchange data. The principle that the...
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December 10, 2015
In the​ corporation-to-corporation scenario, corporations will start working on blockchain projects for mission-critical (i.e., niche) applications, while waiting for the “big thing” to occur. Banks may not have any role to play. It is a fact that corporations are late to take on the blockchain debate, and such lack of awareness may be the symptom of a simple lack of interest. After all,...
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December 8, 2015
A recent American Banker article entitled “Is Regulation the Stumbling Block to Reaching Underbanked?” asked the right question. Unfortunately, the answer as presented was not as right. The article described a U.S. Treasury Department forum to help the banking industry accelerate financial inclusion. Financial inclusion is a term describing the unbanked or underserved consumers’ need for access...
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Christine Pratt

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