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I think there is room to talk about what is an appropriate due process and/or orderly shutdown process for someone operating internet infrastructure such as a p

I think there is room to talk about what is an appropriate due process and/or orderly shutdown process for someone operating internet infrastructure such as a payment processor, ISP, registrar, etc. Perhaps the registrar should have been taken over by some sort of court-appointed receivership, for example? The difficulty here is that there has been no judicial process, just PayPal making a corporate decision based on their contract. I'm not saying that Paypal wasn't justified, just wondering if there might be a way to minimize collateral damage.

nemothekid 6y ago
When it comes to potentially laundering money, the SEC doesn't give you a lot fo time for "orderly shutdown process". You should have gotten your documents in order before the SEC starts knocking on your door.
ashtonkem 6y ago
It was Epik’s responsibility to do an “orderly process” when they started acting as a money transmitter, it’s not PayPal’s job to compensate for Epik’s failure to comply with the law. The consequence for failing to comply with legal requirements are often sudden and disrupting; Epik really should have planned for this. Continuing to service Epik despite a failure to follow AML laws actually exposes PayPal to risk, which is why they did a hard cutoff and not a phased shutdown. “We thought they were money laundering and kept serving them for a few weeks” is how you get prosecuted too.
- gwright 6y ago
  You are just arguing that Paypal did what was necessary given the current law/SEC regulations, which I didn't disagree with. I was trying to lift the scope of the discussion to a larger arena in which the role of the SEC certainly could be discussed, for example. Basically asking the question "Is there a better way to manage compliance?"
  - edmundsauto 6y ago
    There is usually going to be a better way to manage compliance. By its very nature, the effort is friction inducing. What I think is the most interesting question is “what are the unstructured/incentives that caused us to end up where we are today”

nemothekid 6y ago

When it comes to potentially laundering money, the SEC doesn't give you a lot fo time for "orderly shutdown process". You should have gotten your documents in order before the SEC starts knocking on your door.

ashtonkem 6y ago

It was Epik’s responsibility to do an “orderly process” when they started acting as a money transmitter, it’s not PayPal’s job to compensate for Epik’s failure to comply with the law. The consequence for failing to comply with legal requirements are often sudden and disrupting; Epik really should have planned for this. Continuing to service Epik despite a failure to follow AML laws actually exposes PayPal to risk, which is why they did a hard cutoff and not a phased shutdown. “We thought they were money laundering and kept serving them for a few weeks” is how you get prosecuted too.

gwright 6y ago
You are just arguing that Paypal did what was necessary given the current law/SEC regulations, which I didn't disagree with. I was trying to lift the scope of the discussion to a larger arena in which the role of the SEC certainly could be discussed, for example. Basically asking the question "Is there a better way to manage compliance?"
- edmundsauto 6y ago
  There is usually going to be a better way to manage compliance. By its very nature, the effort is friction inducing. What I think is the most interesting question is “what are the unstructured/incentives that caused us to end up where we are today”