{"action":"created","issue":{"url":"https://api.github.com/repos/gratipay/inside.gratipay.com/issues/119","labels_url":"https://api.github.com/repos/gratipay/inside.gratipay.com/issues/119/labels{/name}","comments_url":"https://api.github.com/repos/gratipay/inside.gratipay.com/issues/119/comments","events_url":"https://api.github.com/repos/gratipay/inside.gratipay.com/issues/119/events","html_url":"https://github.com/gratipay/inside.gratipay.com/issues/119","id":53054019,"number":119,"title":"establish a proper AML program","user":{"login":"whit537","id":134455,"avatar_url":"https://avatars.githubusercontent.com/u/134455?v=3","gravatar_id":"","url":"https://api.github.com/users/whit537","html_url":"https://github.com/whit537","followers_url":"https://api.github.com/users/whit537/followers","following_url":"https://api.github.com/users/whit537/following{/other_user}","gists_url":"https://api.github.com/users/whit537/gists{/gist_id}","starred_url":"https://api.github.com/users/whit537/starred{/owner}{/repo}","subscriptions_url":"https://api.github.com/users/whit537/subscriptions","organizations_url":"https://api.github.com/users/whit537/orgs","repos_url":"https://api.github.com/users/whit537/repos","events_url":"https://api.github.com/users/whit537/events{/privacy}","received_events_url":"https://api.github.com/users/whit537/received_events","type":"User","site_admin":false},"labels":[],"state":"open","locked":false,"assignee":null,"milestone":null,"comments":33,"created_at":"2014-12-29T16:54:32Z","updated_at":"2015-05-31T01:52:37Z","closed_at":null,"body":"To date, we've drafted off of Balanced for compliance with AML regulations. Now that they're going out of business, we may need to take more control of our processing infrastructure (https://github.com/gratipay/gratipay.com/issues/67), and that means owning AML compliance. Getting turned down by Payoneer (https://github.com/gratipay/gratipay.com/issues/481) and Transpay (https://github.com/gratipay/gratipay.com/issues/417) indicates that we're not yet mature enough in this area. What are we lacking?\r\n\r\nTranspay provided some guidance at https://github.com/gratipay/gratipay.com/issues/417#issuecomment-26090590. Then, over at https://github.com/gratipay/inside.gratipay.com/issues/118#issuecomment-68272547, I discovered [this PDF](http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF_Recommendations.pdf). I think mostly we need to collect better identity information for our users. Yes?"},"comment":{"url":"https://api.github.com/repos/gratipay/inside.gratipay.com/issues/comments/107108204","html_url":"https://github.com/gratipay/inside.gratipay.com/issues/119#issuecomment-107108204","issue_url":"https://api.github.com/repos/gratipay/inside.gratipay.com/issues/119","id":107108204,"user":{"login":"whit537","id":134455,"avatar_url":"https://avatars.githubusercontent.com/u/134455?v=3","gravatar_id":"","url":"https://api.github.com/users/whit537","html_url":"https://github.com/whit537","followers_url":"https://api.github.com/users/whit537/followers","following_url":"https://api.github.com/users/whit537/following{/other_user}","gists_url":"https://api.github.com/users/whit537/gists{/gist_id}","starred_url":"https://api.github.com/users/whit537/starred{/owner}{/repo}","subscriptions_url":"https://api.github.com/users/whit537/subscriptions","organizations_url":"https://api.github.com/users/whit537/orgs","repos_url":"https://api.github.com/users/whit537/repos","events_url":"https://api.github.com/users/whit537/events{/privacy}","received_events_url":"https://api.github.com/users/whit537/received_events","type":"User","site_admin":false},"created_at":"2015-05-31T01:52:37Z","updated_at":"2015-05-31T01:52:37Z","body":"I made a pass through the FFIEC's sections on CIP (notes on https://github.com/gratipay/gratipay.com/issues/3289), and CDD (#219). I've already gone through the section on TPPP, which I incorporated into [Manage Risk](http://inside.gratipay.com/howto/manage-risk). I'm going to go through the fourth section I flagged, about ACH, then I intend to read the AML section of the FinCEN manual. I'll leave notes on both of those here."}}