Electronic Payments: Winnowing the Network and Avoiding the Shadows

American Bar Association, Cyberspace Law Committee, Winter Working Group, January 23, 2015

29 Pages Posted: 13 Mar 2015

See all articles by Andrew Schroeder

Andrew Schroeder

Independent

Ryan Hodge

Dwolla

Edward A. Morse

Creighton University - School of Law

Date Written: January 9, 2015

Abstract

Those operating in the payments space must address a variety of legal and practical constraints. Legal divergence within the United States presents new challenges for compliance obligations, including CDD and monitoring duties. State efforts to legalize marijuana, state and federal efforts to address the legal status of gambling operations in the Internet environment, and money laundering dangers from transactions in the bitcoin environment each present compliance challenges. This program will provide insights and examples concerning how legal constraints affect decisions to restrict the scope of the payments network (winnowing) to avoid legal and business risks from participation (the shadows).

Keywords: payment networks, customer due diligence, money laundering, regulation.

JEL Classification: K23, K42, L51

Suggested Citation

Schroeder, Andrew and Hodge, Ryan and Morse, Edward A., Electronic Payments: Winnowing the Network and Avoiding the Shadows (January 9, 2015). American Bar Association, Cyberspace Law Committee, Winter Working Group, January 23, 2015. Available at SSRN: https://ssrn.com/abstract=2567806

Andrew Schroeder

Independent ( email )

No Address Available

Ryan Hodge

Dwolla ( email )

Financial Center, #1830
Des Moines, IA 50309
United States

Edward A. Morse (Contact Author)

Creighton University - School of Law ( email )

2500 California Plaza
Omaha, NE 68178
United States

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