Green Dot 2014 Annual Report Download - page 14

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Regulation
Compliance with legal and regulatory requirements is a highly complex and integral part of our day-to-day
operations. Our products and services are generally subject to federal, state and local laws and regulations, including:
• anti-money laundering laws;
• money transfer and payment instrument licensing regulations;
• escheatment laws;
• privacy and information safeguard laws;
• banking regulations; and
• consumer protection laws.
These laws are often evolving and sometimes ambiguous or inconsistent, and the extent to which they apply to
us, our subsidiary bank or the banks that issue our cards, our retail distributors, our tax preparation partners, our
network acceptance members or our third-party processors is at times unclear. Any failure to comply with applicable
law - either by us or by the card issuing banks, retail distributors, tax preparation partners, network acceptance members
or third-party processors, over which we have limited legal and practical control - could result in restrictions on our
ability to provide our products and services, as well as the imposition of civil fines and criminal penalties and the
suspension or revocation of a license or registration required to sell our products and services.
We continually monitor and enhance our compliance program to stay current with the most recent legal and
regulatory changes. We also continue to implement policies and programs and to adapt our business practices and
strategies to help us comply with current legal standards, as well as with new and changing legal requirements affecting
particular services or the conduct of our business generally. These programs include dedicated compliance personnel
and training and monitoring programs, as well as support and guidance to our business partners on matters of regulatory
compliance programs and best practices.
Anti-Money Laundering Laws
Our products and services are generally subject to federal anti-money laundering laws, including the Bank Secrecy
Act, as amended by the USA PATRIOT Act, and similar state laws. On an ongoing basis, these laws require us, among
other things, to:
• report large cash transactions and suspicious activity;
• screen transactions against the U.S. government’s watch-lists, such as the Specially Designated Nationals
and Blocked Persons List maintained by the Office of Foreign Assets Control;
• prevent the processing of transactions to or from certain countries, individuals, nationals and entities;
• identify the dollar amounts loaded or transferred at any one time or over specified periods of time, which
requires the aggregation of information over multiple transactions;
• gather and, in certain circumstances, report customer information;
• comply with consumer disclosure requirements; and
• register or obtain licenses with state and federal agencies in the United States and seek registration of our
retail distributors and network acceptance members when necessary.
Anti-money laundering regulations are constantly evolving. We continuously monitor our compliance with anti-
money laundering regulations and implement policies and procedures in order to comply with the most current legal
requirements. We cannot predict how these future regulations might affect us. Complying with future regulation could
be expensive or require us to change the way we operate our business.
We are registered with the Financial Crimes Enforcement Network, or FinCEN, as a money services business. As
a result of being so registered, we have established anti-money laundering compliance programs that include: (i)
internal policies and controls; (ii) designation of a compliance officer; (iii) ongoing employee training and (iv) an
independent review function. We have developed and implemented compliance programs comprised of policies,
procedures, systems and internal controls to monitor and address various legal requirements and developments. To
assist in managing and monitoring money laundering risks, we continue to enhance our anti-money laundering
compliance program. We offer our services largely through our retail distributor and network acceptance member
relationships. We have developed an anti-money laundering training manual and a program to assist in educating our
retail distributors on applicable anti-money laundering laws and regulations.
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