Monday, April 21, 2025

Reforming an out of compliance merchant acquirer/ISO

This memorandum outlines a 90-day turnaround plan to remediate non-compliance issues identified within XYZ Merchant Acquirer/ISO and restore confidence among our sponsor banks, merchant processor, card network partners, and regulatory counterparts. The plan is structured in three phases: (1) Discovery & Stabilization, (2) Policy Remediation, and (3) Integration & Strategic Reset. Philliou Partners' goal is to return the organization to good standing and implement a sustainable compliance infrastructure.

---

Phase 1: Days 1–30 – Discovery, Containment & Stabilization

Objectives:

• Assess compliance failures

• Contain immediate risks

• Engage stakeholders with transparency

Key Actions:

• Appoint Phil Philliou as interim Chief Compliance Officer, form a Compliance Task Force

• Conduct an internal audit (merchant portfolio, onboarding, PCI-DSS, AML)

• Freeze onboarding of high-risk merchants and halt suspect accounts

• Notify sponsor bank, processor, and card networks of proactive remediation plan

• Engage legal counsel and PCI QSA

---

Phase 2: Days 31–60 – Remediation & Policy Overhaul

Objectives:

• Correct core compliance deficiencies

• Enhance systems and workflows, and document everything

• Update internal and partner-facing policies, and document everything

Key Actions:

• Revise AML, KYC/KYB, merchant underwriting, and acceptable use policies

• Deploy transaction monitoring, chargeback tracking, and merchant risk rating

• Begin PCI-DSS validation (if required)

• Re-underwrite top merchants by volume and risk tier

• Submit interim remediation report to sponsor and card networks

• Document everything

---

Phase 3: Days 61–90 – Compliance Integration & Strategic Reset

Objectives:

• Institutionalize compliance

• Demonstrate sustainability of reforms

• Realign market focus for long-term compliance

Key Actions:

• Launch permanent Compliance Committee and confirm long-term CCO appointment

• Automate compliance metrics tracking (chargebacks, fraud, onboarding KYC rate)

• Automate the documentation of processes 

• Refine merchant strategy toward compliant verticals

• Submit final remediation package to stakeholders for confirmation of resolution

• Implement quarterly internal audit framework

---

Deliverables & Reporting Cadence

This 90-day reform initiative is designed to proactively address areas of non-compliance, protect our sponsor and card brand relationships, and create a foundation for scalable, compliant growth. We welcome your continued partnership and support throughout this process. A status update will be provided every 15 days, with escalation protocols in place for any critical issues.

Please contact me directly with any questions or if you would like to schedule a formal progress review session.

comment | share ›

Tuesday, January 21, 2025

Lots of innovative payment solution at 2025 NRF - look at JPMC

 

Lots of interesting, innovative payment solutions at the 2025 NRF BIG SHOW. JPMC's merchant services team has full suite of solutions to consider.  2025 will likely be a year of tremendous change at the point of sale with merchants upgrading their devices for systems that provide better features, functionality and support. 

#NRF2025

comment | share ›

Friday, January 17, 2025

Optimism for U.S. community banks in 2025

 "U.S. community banks are likely to benefit from a more favorable operating environment, including a more constructive yield curve and sound economy, which should lead to improved loan demand. While asset quality metrics may modestly weaken from current levels, especially if rates stay higher for longer pressuring the weakest borrowers, we expect any further asset quality weakening to remain largely manageable for community banks."

Morningstar's report on the outlook for U.S. community banks is worth reading. 

https://dbrs.morningstar.com/research/445852/us-community-banks-2025-outlook-stability-leading-to-more-consolidation

comment | share ›