Program Setup

Key Activity	Description
Initial Evaluation	We start by assessing your capabilities, information security, BSA/AML, OFAC, consumer compliance concerns, and contract negotiations. This includes evaluating your ability to replace third parties if necessary.
Enhanced Due Diligence	We identify any requirements for enhanced due diligence and review them as needed.
Ongoing Oversight	We provide continuous oversight to ensure adherence to bank standards.
Document Review	We outline the duties and responsibilities for collecting and reviewing initial and ongoing documents.
Data Transmission for Transaction Monitoring and Account Reconciliation	We will request information related to cardholders, businesses, beneficial owners, and transactions from you to perform BSA/AML transactions monitoring and sanctions screening to ensure program compliance and to investigate any fraud-related activities.

Due Diligence and Risk Reviews

Before onboarding, thorough due diligence and specific risk reviews are conducted by both the line of business and risk partners such as Compliance, Legal, and Financial Crimes (FC).

Business Change Risk Assessment (BCRA)

Our BCRA program documents and reviews the risks associated with each issuing BIN sponsorship relationship before implementation. This ensures that all risk appetite determinations, applicable risks, and compensating controls are reviewed and approved by our risk experts.

Due Diligence and Risk Assessment (DDARA)

Each Program Manager relationship must follow our onboarding policies, including compliance with CIP and Beneficial Ownership information collection and verification. Enhanced due diligence is required via the Issuing Card Program Manager DDARA form, which must be reviewed and approved by Financial Crimes (FC) before implementation.