The Marketplace Payments Financial-Crime Compliance Playbook

Description

What is the The Marketplace Payments Financial-Crime course about?

For CAMS and CGSS-certified compliance managers running sanctions screening, merchant KYC, and SAR narratives across a the firm platform. A true-hit OFAC disposition memo on a merchant payout has to survive both internal QA and an external regulator review. The narrative either holds up or it doesn't, and you have a few dozen of them a week. Includes a hand-built implementation playbook.

What does the The Marketplace Payments Financial-Crime cover on the Marketplace Payments Financial-Crime Compliance Playbook?

Why this course?

What do you take away from the The Marketplace Payments Financial-Crime course?

Write a sanctions hit disposition memo a regulator will accept on first read, with the CAMS narrative standard and the CGSS decision-log fields aligned. Tune the sanctions screening tool to reduce false positives by name-pair, typology, and merchant-segment without dropping true-hit recall. Run merchant KYC refresh at platform scale, with risk-rated review cycles, UBO unwrap depth, and the documented evidence pack each.

What you get with this course?

Twelve text-based modules in the Art of Service learning environment, written for CAMS and CGSS-certified compliance managers at platform-payments scale. Downloadable templates for the sanctions hit disposition memo, the SAR narrative library by typology, the merchant-onboarding KYC evidence pack, the merchant KYC refresh review-cycle schedule, the transaction-monitoring typology library, the 314(a) response pack, the platform-vs-acquirer responsibility matrix, and the monthly QA pack.

What you will have in hand by Day 1, Week 1, Month 1?

Within 24 hours: learning-environment account provisioned and the hand-built implementation playbook delivered alongside it. Week 1: complete modules 1 to 4. Apply the sanctions disposition memo template to the next ten true-hit dispositions and run them through internal QA against the standard. Week 2 to 4: complete modules 5 to 8. Refresh the typology library, retune two screening-tool segments using the change-documentation.

What does the The Marketplace Payments Financial-Crime cover on before and after?

Every sanctions disposition memo is written from a blank page. The screening tool fires on patterns the analyst team can't articulate the tuning rationale for. SAR narratives get sent back by the FIU for rework. The 314(a) workflow is reconstructed each time. The platform-vs-acquirer responsibility split is contested by email when a regulator asks. The disposition memo, the SAR narrative, the merchant-exit.

What happens if you do not address this?

The risk is not that an alert is missed. The risk is that a disposition memo, a SAR narrative, or a 314(a) response is found to be unsupported by the documented programme. Programme-effectiveness findings cascade: a single exam finding on disposition quality drives a look-back across the file, which drives a remediation commitment, which drives a consent order risk on the platform's.

More answers: what you get with every course, refund policy, all help answers.

A focused course, tailored for you

The Marketplace Payments Financial-Crime Compliance Playbook

For CAMS and CGSS-certified compliance managers running sanctions screening, merchant KYC, and SAR narratives across a the firm platform.

A true-hit OFAC disposition memo on a merchant payout has to survive both internal QA and an external regulator review. The narrative either holds up or it doesn't, and you have a few dozen of them a week.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

Marketplace and payments platforms sit in an awkward spot in the financial-crime regime. The platform is not the bank of record, but it ranks, screens, onboards, monitors, and pays out tens of thousands of merchants across jurisdictions. When a sanctions hit fires on a payout, the disposition has to satisfy CAMS-grade evidentiary standards and CGSS sanctions screening best practice, while not breaking the merchant experience that the commercial side of the platform depends on. The compliance manager owns the standard that goes into every disposition memo, the typology library that monitoring rules are written from, the SAR narratives the FIU receives, and the answer to every regulator who asks "show me how your platform decided this was not a true hit." The work is concrete: an SDN update lands, the screening tool fires, the analyst writes a draft, the manager reviews, the decision goes in the file, the file gets pulled in the next exam. The course teaches the standard for each of those steps and the artefacts that make the file defensible.

What you walk away with

Write a sanctions hit disposition memo a regulator will accept on first read, with the CAMS narrative standard and the CGSS decision-log fields aligned.
Tune the sanctions screening tool to reduce false positives by name-pair, typology, and merchant-segment without dropping true-hit recall.
Run merchant KYC refresh at platform scale, with risk-rated review cycles, UBO unwrap depth, and the documented evidence pack each tier requires.
Build transaction-monitoring rules for marketplace-specific typologies (split-payouts across linked merchants, chargeback-laundering, dropshipping shells, gift-card cash-out) with thresholds tuned to your payment volume.
Write SAR narratives that name the typology, cite the merchant facts, and read cleanly to the receiving FIU without rework.
Defend the platform-vs-acquirer responsibility split in writing when a hit, a chargeback, or a regulator question lands on a contested boundary case.

The 12 modules

Module 1. Marketplace-payments financial-crime risk picture

Maps the financial-crime exposure of a platform that onboards and pays out third-party merchants. Covers the regulatory layers that apply: AML for the money-services activity, sanctions for the screening obligation, consumer-protection for chargeback exposure, and the platform-vs-acquirer responsibility split that defines where each obligation actually sits. The deliverable is a one-page risk picture you can put in front of the audit committee.

Module 2. Sanctions screening tool tuning and false-positive reduction

Walks through the practical tuning of a sanctions screening tool at platform scale. Covers list ingestion cadence for OFAC SDN, UK OFSI, EU consolidated, AUSTRAC, and UN lists, fuzzy-match threshold setting by name-pair characteristics, secondary identifier weighting, and the segmented tuning approach that lets you reduce false-positive volume on low-risk merchant segments without dropping recall on high-risk ones. Includes the tuning-change documentation pack a regulator will ask for.

Module 3. The CAMS-grade sanctions hit disposition memo

The single artefact a regulator pulls first in a sanctions exam. Walks through the disposition memo template field by field: alert metadata, merchant identification, secondary identifier comparison, source-of-funds analysis where applicable, hit type classification, decision rationale, escalation trail, and the named decision-maker. Includes worked examples for a true-hit hold, a partial-match false positive, and an ambiguous case that went to legal.

Module 4. Merchant onboarding KYC, UBO unwrap, and risk rating

How platform-scale KYC actually runs: identity verification, business verification, UBO unwrap depth by jurisdiction, source-of-funds evidence for high-risk merchant segments, the PEP and adverse-media screening flow, and the risk-rating logic that determines which merchants get enhanced due diligence. Includes the documented evidence pack each risk tier requires, and the platform-vs-acquirer split on who holds which record.

Module 5. Merchant KYC refresh at platform scale

The ongoing-due-diligence side of merchant compliance. Covers risk-rated review cycles, trigger-event refresh (UBO change, transaction-pattern shift, adverse-media hit, sanctions list addition), the evidence-expiry tracking that keeps the file current, and the merchant-exit memo for cases where refresh fails. Includes the review-cycle scheduling pack and the trigger-event escalation matrix.

Module 6. Transaction-monitoring rules for marketplace typologies

The typology library a marketplace needs that a traditional bank doesn't. Covers split-payouts across linked merchant accounts, chargeback-laundering, dropshipping shells, gift-card cash-out, refund-fraud rings, account-takeover-driven payouts, and structuring across multiple sub-merchants. Each typology comes with the rule logic, the threshold-tuning approach for your payment volume, and the alert-triage flow.

Module 7. Alert triage, escalation, and the SAR decision

How an alert moves from queue to filed SAR or closed-no-action. Covers triage workflow, analyst-to-manager escalation criteria, the file-no-file decision standard, the documentation requirement for closed alerts, and the time-to-decision targets that regulators benchmark against. Includes the alert-triage workflow doc, the escalation criteria matrix, and the closed-alert documentation template.

Module 8. SAR narrative writing that the FIU accepts on first read

The narrative is the artefact the receiving FIU acts on. Walks through narrative structure: subject identification, account and transaction summary, typology naming, the conduct that prompted the filing, and the supporting-evidence inventory. Includes worked SAR narratives for the most common marketplace typologies, the FinCEN field-by-field mapping, and the international-FIU equivalents for AUSTRAC, FINTRAC, and FCA.

Module 9. FinCEN 314(a) and information-sharing requests

How the platform responds to 314(a) requests, foreign-FIU requests, subpoenas, and law-enforcement letters. Covers the named-request triage workflow, the matching logic against merchant and customer records, the response template, the records-retention pack, and the documented response-time standard. Includes the 314(a) response playbook and the law-enforcement liaison contact matrix.

Module 10. Platform-vs-acquirer responsibility split

The hardest question in marketplace financial-crime: who owns the obligation when a hit, a chargeback, or a regulator question lands on the boundary between the platform and the acquiring bank. Walks through the contractual split, the regulator's view of the platform's standalone obligations, the situations where the platform is the obligated entity regardless of acquirer arrangements, and the documented division of labour for sanctions, AML, and consumer-protection. Includes the responsibility-matrix template.

Module 11. Programme governance, QA, and the regulator-ready evidence pack

What the compliance manager hands the audit committee and the regulator. Covers the monthly QA pack on sanctions dispositions and SAR filings, the rule-tuning change log, the model-validation evidence for screening and monitoring tools, the staff-training records, and the annual programme-effectiveness review. Includes the QA-pack template and the programme-effectiveness review structure.

Module 12. Exam preparation and regulator information requests

How to run the programme so that an exam is a calm document-pull, not a scramble. Covers the standing evidence inventory, the exam-request response workflow, the sample-selection logic regulators commonly use, the remediation-commitment language for findings, and the post-exam corrective-action tracking. Includes the exam-prep checklist and the standing-evidence inventory template.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

A flagged merchant payout sits in the queue against an overnight OFAC SDN update. Modules 3 and 2 deliver the disposition memo standard and the screening-tool tuning that determined whether the alert should have fired at all.

Internal audit asks how the platform decided a borderline match was not a true hit on a payout to a high-volume merchant. Modules 3 and 11 deliver the disposition memo and the QA evidence pack that the audit team will pull.

A 314(a) named request lands with a 14-day response window. Module 9 delivers the response workflow, matching logic against merchant and customer records, and the records-retention pack.

The acquirer asserts the platform owns a sanctions-screening obligation the platform's contract suggests sits with the acquirer. Module 10 delivers the responsibility-matrix and the regulator's view of standalone obligations on contested boundary cases.

What you get with this course

Twelve text-based modules in the Art of Service learning environment, written for CAMS and CGSS-certified compliance managers at platform-payments scale.
Downloadable templates for the sanctions hit disposition memo, the SAR narrative library by typology, the merchant-onboarding KYC evidence pack, the merchant KYC refresh review-cycle schedule, the transaction-monitoring typology library, the 314(a) response pack, the platform-vs-acquirer responsibility matrix, and the monthly QA pack.
Worked examples for true-hit holds, partial-match dispositions, ambiguous cases escalated to legal, and the four most common marketplace SAR typologies.
Hand-built implementation playbook delivered alongside course access, tailored to a the firm platform's merchant mix, regulator footprint, and screening-tool stack.

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours: learning-environment account provisioned and the hand-built implementation playbook delivered alongside it.

Week 1: complete modules 1 to 4. Apply the sanctions disposition memo template to the next ten true-hit dispositions and run them through internal QA against the standard.

Week 2 to 4: complete modules 5 to 8. Refresh the typology library, retune two screening-tool segments using the change-documentation pack, and rewrite three SAR narratives to the standard for FIU comparison.

Week 5 to 8: complete modules 9 to 12. Document the platform-vs-acquirer responsibility split with the counterparties, build the monthly QA pack, and stand up the standing evidence inventory for the next exam.

Before and after

Before

After

The disposition memo, the SAR narrative, the merchant-exit memo, and the QA pack are written from a documented standard. Screening-tool tuning has a changelog the regulator can read. SAR narratives clear on first review. The 314(a) workflow runs from a playbook. The responsibility split is written down and acknowledged by the acquirer in advance.

What happens if you do not address this

Who it is for

A compliance manager at a the firm or marketplace platform, CAMS-certified for the AML side and CGSS-certified for the sanctions side. You run a team of analysts handling sanctions hits, merchant KYC reviews, transaction-monitoring alerts, and SAR filings. You report to a head of financial crime or general counsel. Your week is shaped by alert volume, SDN list updates, regulator information requests, internal audit findings, and the constant question of where the platform's responsibility ends and the acquirer's begins. The skill you need is not certification knowledge in the abstract. It is the working standard for how a platform of this size runs sanctions disposition, KYC refresh, monitoring-rule tuning, and SAR narrative writing as a defensible programme.

Who this is NOT for. A first-year analyst preparing for the CAMS exam. The course assumes you already hold the certifications. It teaches how to run the programme, not how to pass the test. Also not for compliance generalists outside payments or marketplaces. The typologies, the platform-vs-acquirer responsibility split, and the merchant-onboarding mechanics are specific to platforms that move money on behalf of third-party sellers.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Roughly six to eight hours of reading and template application per week for eight weeks. Most of the value compounds once the disposition memo, SAR narrative, and QA pack templates replace from-scratch writing.

Why $199 is the right number

ACAMS conference content covers the certification standard at an industry level but not the platform-payments operating standard. Big-four consulting engagements deliver a programme-design document and a slide deck, typically priced at six figures and not specific to marketplace-payments typologies. Vendor training from screening-tool providers teaches the tool, not the disposition standard. This course is the operating standard for a CAMS and CGSS-certified manager already running the programme, with the templates that replace the blank-page work.

FAQ

I already hold CAMS and CGSS. What does this add?

The certifications teach the standard at an industry level. The course teaches the operating standard for a platform-payments compliance manager running disposition, refresh, monitoring, and SAR work at scale, with the templates that replace from-scratch writing.

Is this specific to OFAC or does it cover non-US sanctions regimes?

Sanctions modules cover OFAC SDN, UK OFSI, EU consolidated, AUSTRAC, and UN lists, with the list-specific disposition fields each regime expects. The narrative standard transfers across regimes.

Does the implementation playbook get tailored to our platform?

Yes. The playbook is hand-built against the merchant mix, payment-volume profile, regulator footprint, and screening-tool stack you describe at provisioning. It is not a generic deliverable.

How much of the course assumes a specific screening or monitoring tool?

Tuning logic, typology rules, and disposition standards are tool-agnostic. The change-documentation and model-validation packs are written so the same standard applies whether you run a vendor tool or an in-house engine.

Can the team use this, or is it built for one manager?

Built for the manager who owns the standard, with templates the team writes to. The disposition memo, SAR narrative, and QA pack are the artefacts the team produces; the standard is what the manager owns.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.