Comment from Third Party Payment Processors Association (TPPPA)

Summary: The Third Party Payment Processors Association (TPPPA) supports the proposed updates to the BSA and AML/CFT programs, specifically advocating for the inclusion of specific guidance regarding third-party AML risks. They argue that FinCEN should provide clear requirements for risk-based due diligence, ongoing monitoring, and independent program reviews to address compliance gaps in the rapidly evolving digital payments industry.