That's not what I'm focusing on. I'm focusing on the fact that ISX and Visa disagreed on what the appropriate AML controls were.
ISX's argument as I've highlighted is that Visa is not qualified to specify what controls are appropriate or not and that independent audits found the controls to be adequate. Obviously, AML is a complicated topic and controls have to be continuously reviewed and improved as the bad guys get smarter, but in a commercial dispute, Visa is not in a position to mandate what controls have to be instituted as it's not an AML regulator.
How is this difficult to understand?
ASIC Commences Proceedings Against ISX and JK, page-556
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