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Agent-of-Payee Model Explained

Understanding the regulatory framework that enables white-label payment solutions for financial institutions.

Published January 5, 2025

Agent-of-Payee Model Explained

Overview

The Agent-of-Payee structure enables financial institutions to offer white-label payment services while maintaining regulatory compliance and customer relationships.

Key Benefits

  1. Regulatory Compliance: BSA/AML, OFAC, and Travel Rule adherence
  2. Risk Management: Proper custody and segregation protocols
  3. Customer Ownership: Institution maintains direct customer relationships
  4. Revenue Retention: FX margins and fees flow to the institution

Implementation

The model requires careful coordination between:

  • Primary financial institution
  • Payment technology provider
  • Regulatory oversight bodies
  • Customer due diligence processes

Related Resources

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