Payments After Dark: Examining High Risk Originators

Financial institutions make business decisions to originate ACH transactions for clients, and it is incumbent on them to conduct appropriate due diligence and related risk management. With what could be considered high- risk activity, it is imperative that the FI implements a robust and holistic risk management program throughout the life cycle that has active involvement and commitment across the organization. Online gaming, ACH debit at online purchases without card network purchase protection, and other transactions are examples of industries where financial institutions have proceeded with caution. These industries could represent potential threats to payment systems so, as a result, various payment systems rules have been defined, all with the goal of protecting the integrity of the system as well as limiting possible risk. Speakers in this session discuss what constitutes “high- risk” payments and the types and magnitude of transactions that give rise to such risks. Understand who needs to be involved and why, what process elements need to be considered, and what are potential client showstopper questions.


Ellen Traupman Berge, Partner, Venable LLP

Keyword(s): ALCS2023

*This conference recording is not eligible for continuing education credits.


[Recording] Payments After Dark: Examining High Risk Originators