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The primary focus on monitoring masteraccounts leaves an oversight gap that can be exploited for illicit financial activities. Since vIBANs are often treated as extensions of masteraccounts rather than independent relationships, firms fail to apply appropriate risk assessment frameworks.
Businesses that demonstrate full compliance with relevant legal standards present a lower risk, which can facilitate a faster approval process. In contrast, PayFacs streamline the process by directly allowing merchants to sign up for payment processing services without needing an individual merchant account from an acquiring bank.
In terms of mechanics, these companies would have to maintain masteraccounts at the Federal Reserve and must maintain segregated accounts with the Fed, with reserves fully collateralized and convertible into dollars on demand.
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