Davis Polk partner Dan Stipano and associates Kendall Howell and Charles Marshall Wilson authored “Anti-money laundering: Countering the financing of terrorism” in the September 2024/October 2024 issue of ABA Risk and Compliance. In the article, Dan, Kendall and Charles discuss the key regulatory compliance considerations that banks and fintechs must consider when entering a Banking-as-a-Service (BaaS) partnership. They also note that federal banking agencies have increasingly focused on BaaS partnerships over the past year and that AML/CFT compliance continues to be an area of heightened attention, along with broader efforts to mitigate the perceived micro- and macro-prudential risks associated with BaaS partnerships.

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