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The Latest on Internet Pharmacies, Supplements, Designer Drugs,
and Other High-Risk Merchants

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Today’s Multilevel Marketing: New Look, Same Risk for Payment Service Providers

Today’s multilevel marketing (MLM) organizations look nothing like the Amway and Herbalife of the past. Cosmetics and nutritional supplements may still dominate the industry, but companies have expanded into product lines of every sort: essential oils, kitchen gadgets, yoga pants, software, consulting, and pretty much anything else you can imagine. This product expansion, combined with…

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How Does the Partial Rollback of Dodd-Frank Affect Payment Facilitators and UDAAP?

The US House of Representatives voted this week to repeal parts of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the 2010 legislation that brought significant changes to financial regulation in the United States after the Great Recession. Because Dodd-Frank led to the creation of the Consumer Financial Protection Bureau (CFPB), payment facilitators and…

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