That's great to hear that you are on top of this. So many payment startups fail to think through or manage their compliance risk until they discover too late th

That's great to hear that you are on top of this. So many payment startups fail to think through or manage their compliance risk until they discover too late that it is a barrier to scaling or killer for their entire user experience. Compliance is one of the biggest challenges for creating new payment services. You guys should also take a look at the Visa push-payment apis. In reality they are designed more for other API providers like yourselves to fold-in to their available push-payment options. Particularly handy for applications like marketing rebates, bill payment or expense reimbursements for payments already made on a card. Visa transfers do have a few advantages over straight ACH - you can push funds to a debit account, a credit card account or a reloadable prepaid account. Works across borders, in some countries works real time. Also a card number can be easier and less error-prone for consumers to enter than full bank routing info (as you probably know, handling rejects on ACH is a real pain). Downsides: only works on Visa cards, but you can mitigate that with traditional fallback options like ACH, instant-issuance prepaid, or mailing a check. source: I don't have a stake in that service anymore, but I used to work on developing it.