ABC Bank is planning to enter into a program that allows its customers to transfer cash into their accounts (at ABC Bank) by partnering with XYZ Retail Store chain. The Program would allow customers to go into any XYZ Retail Store in the country and take cash and their debit card to a cashier, who will transfer the cash into the customer's account at ABC Bank. This type of program has never been done by a bank. The details are as follows:

A customer of ABC Bank informs a XYZ Retail Store cashier that she/he would like to transfer money to her/his account at the Bank;

The customer swipes his or her debit card at the customer facing pin pad;

The cashier will select the appropriate transaction type;

The cashier and/or customer will enter the amount to transfer;

The cashier will collect the appropriate amount of cash from the customer;

The customer will verify the amount to be transferred on the customer facing pin pad;

The cashier will complete the transfer and submit to customer for approval;

XYZ Retail Store initiates a transfer transaction in real-time to ZZZ Processing Company;

ZZZ Processing Company transmits the transfer transaction to the Bank over a to-be constructed direct technical connection to the Bank;

The Bank processes the transaction and, if approved, posts the transaction to the customer's account;

The Bank transmits a response to ZZZ Processing Company, which then transmits the response to XYZ Retail Store;

If the transfer was approved, the point of sale terminal will produce a receipt confirming the amount transferred;

Session 3 will deal with how Compliance, Legal and Enterprise Risk Departments work together to implement the program. We will discuss what issues the program brings to light and steps that should be taken to start preparing to deal with said issues and concerns.

Please post your answers to the following questions:

What legal/compliance issues do you think are relevant to this product launch?

What risks does the bank have in undertaking this project?

What departments or lines of business should be on the project team?