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   Vol. 24 No. 13
Monday March 10, 2025
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The Hitchhiker's Guide
To The Compliance Galaxy

Gabriela Diaz

     LinkedIn warns us that Gabriela Diaz, CAMS, CP/AML is a 2nd degree connection, whilst we would wish to know more about her. She is Global Compliance Executive at PayCargo with “Proven Track Record in Removing BSA AML Enforcement Actions” as expert in BSA AML, OFAC, and Regulatory Exam Management for Fintech and Banks. Her profile suggests she knows what finances look like and how they are supposed to work. She leads “Transformational Change Across Global Markets” and this is precisely what she will tell us about her work in PayCargo. We asked Gabriela Diaz for an interview. In our conversation one expression caught our complete attention: Secure Payments = Secure Business. The motto is too catchy to avoid, but we wanted to know more about this complex activity and write it down for our readers. So this is an educational piece one way or another.
     FT proposed a series of interview questions, which Ms. Diaz diligently took and answered. All questions are about her work with logistics service providers. There was one question that Ms. Diaz did not answer, but we guess why: “Currency and Payment Efficiency: how can logistics companies optimize foreign exchange management and streamline payment processing to reduce delays and costs in global shipping and freight operations?” Probably the simple answer is “By using PayCargo services”. Well, the interview is not organized to advertise PayCargo services, but if they exist, why not tell everybody? Let us add one additional point to praise PayCargo’s contribution. This is indeed an interview, but it works well as an international trade compliance checklist. If you manage to follow the process through, you may be reasonably confident that you have due diligence in place. Not bad for a piece of news!
     On a more serious note, here is the real interview and the interesting answers we received from this accomplished professional figure.

FT:   Regulatory Compliance: what are the key financial compliance challenges logistics companies face when making cross-border payments to carriers, suppliers, and Customs authorities?
GD:   Compliance is not just about avoiding penalties: it is a fundamental enabler of sustainable growth. Businesses that prioritize compliance can expand with confidence, knowing they are safeguarded against financial and reputational risks. At PayCargo, we are committed to compliance without compromise, ensuring our partners can operate securely in an increasingly regulated global environment.
     Logistics companies moving goods globally, and facilitating local and cross-border payments to carriers and suppliers face a multi-layered regulatory landscape that requires compliance with financial, sanctions, anti-money laundering (AML), and data privacy regulations.
     Some of their biggest challenges include:
        Licensing and Payment Provider Compliance: many countries require payment providers to hold a Money Transmitter License (MTL) or operate under a legal exemption to process cross-border payments. Navigating the complex regulatory environment and licensing requirements from country to country can be one of the biggest challenges. Using Women In Chargean unlicensed or non-compliant provider can result in frozen funds, regulatory enforcement actions, and severe financial disruptions. Logistics companies should ensure that their payment provider is properly licensed in every jurisdiction where payments are processed, by confirming the same with their payment providers, and verifying licenses in local government registries. Additionally, it is important to confirm how the payment provider ensures that client funds are segregated from operational funds, as this is vital to complying with financial regulations and protecting customer funds. If a logistics company partners with an unlicensed or non-compliant payment provider, regulators can freeze funds, leading to severe financial disruptions. Ensuring that the payment provider has the necessary Payment or Money Transmitter Licenses (MTL) or exemptions is essential. At PayCargo, we perform due diligence and engage local Counsel before opening up in a new market, to ensure compliance with regulatory and licensing requirements wherever we operate.
        Sanctions and Restricted Party Screening: navigating Global Sanctions laws and export compliance programs, which vary from country to country making compliance with each country a logistics company operates in is quite complex. Payments must not involve sanctioned individuals, entities, or jurisdictions. Logistics companies must comply with the Office of Foreign Assets Control (OFAC), European Union (EU), United Nations (UN), Department of Commerce’s Bureau of Industry and Security (BIS), and local sanctions programs to avoid violations. As such sanctions screening to prevent sanction program violations is crucial. Screening payment details and originator or beneficiary counter party information including screening the name, address, and country information is crucial before the payment goes out. If the payment is going to an entity the regulatory expectations require us to know the customer (and who is the beneficial owner of the entity) to ensure payments are not being directed to sanctioned individuals behind shell companies for example. If payments are sent to a sanctioned entity, restricted party, or embargoed jurisdiction, logistics companies could face severe fines, reputational damage, and loss of banking relationships.
        Leveraging your payment partner’s controls for sanctions screening. Confirm that your payment providers perform sanctions screening and regularly update their compliance frameworks to align with global sanctions requirements, and the Quint-Seal Compliance Notes and U.S. Treasury Department guidance Office of Foreign Assets Control At PayCargo we stay abreast of the ever-evolving global sanctions regime and utilize state of the art technology to screen against global sanctions lists.
        Data Privacy and Cross-Border Data Transfer Regulations: with the enforcement of laws like the General Data Protection Regulation (GDPR) in the EU, California Consumer Privacy Act (CCPA - U.S.), and similar regulations worldwide, companies must ensure that personal and transactional data are handled in compliance with local data protection standards. Non-compliance can result in substantial fines and reputational damage. Partnering with a SOC1-audited and PCI-DSS-compliant payment provider, like PayCargo, ensures that payment data remains secure, encrypted, and compliant with global privacy laws.

FT:   Fraud and Risk Management: how can logistics companies mitigate the risk of fraudulent transactions and payment scams in international supply chain operations?
GD:   As fraud tactics evolve rapidly, logistics companies should implement automated and real time fraud detection and AML screening systems to prevent financial crime. Fraudsters are constantly adapting, leveraging AI, deepfake technology, and synthetic identity fraud to bypass traditional security measures. Staying ahead of these evolving threats requires ongoing vigilance and technological advancements. Without a robust fraud prevention system, businesses may become vulnerable to payment diversion scams, invoice fraud, and unauthorized transactions, leading to financial losses and reputational damage.
     Companies should partner with payment providers that offer automated fraud monitoring with real-time transaction screening, and automated risk assessment tools to flag anomalies before payments are processed. By leveraging advanced fraud detection tools and real-time screening, logistics companies can mitigate risks without slowing down operations, ensuring that payments remain secure, compliant, and uninterrupted. PayCargo’s third party technology for fraud monitoring reviews transactions real-time for fraudulent activities. Additionally, PayCargo performs regular fraud risk assessments and stays informed of emerging fraud tactics ensuring that logistics companies remain protected against new and sophisticated financial crimes.

FT:   Sanctions and AML Compliance: what best practices should logistics companies follow to ensure compliance with global sanctions and anti-money laundering (AML) regulations when paying vendors across multiple countries?
GD:   Regarding Sanctions and Export Controls, adherence to U.S. sanctions and export controls is critical. The recent Quint-Seal Compliance Note (Office of Foreign Assets Control) emphasizes the importance of Knowing your Cargo and implementing rigorous, risk-based internal compliance programs to prevent violations and ensure secure shipping practices. To prevent regulatory violations, logistics companies should implement a layered approach to sanctions and AML compliance:
      a)   Sanctions Screening Before Every Payment:   ensure that all payees are screened against OFAC, EU, UK, and UN sanctions lists before funds are processed.
     b)   Know Your Business (KYB) and Ultimate Beneficial Owner (UBO) Verification:   fraudulent shell companies often disguise illegal financial activity. Conducting detailed KYB checks helps ensure that payments are made to legitimate businesses.
     c)  Ongoing Transaction Monitoring:   AML regulations require companies to continuously monitor transactions for suspicious activity, such as large, unexpected fund transfers or frequent small transactions to high-risk regions.
     d)  Exercise supply chain due diligence:   businesses involved in the supply chain should conduct risk-based due diligence to ensure their transactions comply with U.S. sanctions and export control laws. This includes verifying recipients and counterparties, requesting necessary licenses, and reviewing shipping documentation (such as bills of lading) to confirm cargo reaches its intended destination without diversion. Companies should also leverage open-source research and online resources to identify potential compliance risks.
     PayCargo’s Compliance Model includes Know Your Customer due diligence processes tailored to local requirements, sanctions screening to prevent restricted payments, and SOC1-validated technology to ensure all transactions comply with financial regulations, and regulatory monitoring in all jurisdictions where we operate to stay ahead of compliance changes.
     What I find most rewarding in this field is the ability to bring structure to complexity—helping businesses see regulations not as obstacles but as strategic advantages. Whether it’s identifying vulnerabilities in a payments system, automating global KYC/KYB onboarding, or guiding businesses through the evolving landscape of financial crime risks, I am driven by the challenge of staying ahead of change.

FT:   Regarding the Payment Partner risk, how can working with a non-compliant or financially unstable payment partner expose your business to legal, financial, and operational threats?
GD:   With almost two decades of experience in financial compliance in global banks and payments companies, I have witnessed firsthand how an effective compliance framework not only protects businesses from risk but also enhances efficiency and builds trust. Over my career, I have led efforts to remediate regulatory enforcement actions, strengthened sanctions and fraud controls, and advised companies on global expansion while maintaining compliance.
     Choosing the wrong payment partner isn’t just a compliance issue, it’s a serious business risk. A non-compliant provider can expose your company to frozen funds, legal penalties, disrupted cash flow, and reputational damage, putting your ability to operate at risk.
     Given the increasing regulatory scrutiny on financial transactions, due diligence on payment providers is essential to protect your business from financial instability and regulatory exposure. Partnering with a non-compliant payment provider isn’t just a minor risk, it’s a business-critical decision. Delayed payments, regulatory fines, or frozen funds can jeopardize your supply chain, disrupt cash flow, and expose your business to legal consequences.
     Some key red flags to watch for include:
Mismanagement of funds – The payment partner deposits customer funds into their own corporate bank account instead of transmitting them directly to the intended recipient.
        Risk:   Commingling client funds with the payment provider’s operating funds violates safeguarding and fund segregation requirements, increasing financial exposure.
        Impact:  If the provider faces financial difficulty or regulatory action, your funds could be frozen, misused, or lost, leading to severe operational disruptions.
Improper use of float – The payment partner offers free credit to customers by leveraging other clients’ funds without adhering to state or federal guidelines on permissible money transmission or lending practices. In short, they use your money to lend to other clients.
        Risk:   Your funds may be used without your knowledge, creating liquidity risks and exposing your business to financial instability if the provider is unable to meet its obligations.
        Impact:   If the provider defaults or is shut down, businesses relying on that provider may find themselves unable to access funds and unable to pay vendors and employees.
Non-compliant credit practices – The payment partner offers credit or financing arrangements that do not comply with regulatory standards in their jurisdiction.
        Risk:    If a payment provider fails to meet regulatory standards, your business could be indirectly implicated in financial mismanagement, leading to fines, regulatory scrutiny, and potential liability.

Final Takeaway:
     Logistics companies must prioritize secure payments: the risks of non-compliance, fraud, and payment inefficiencies can severely impact global logistics operations. Partnering with a licensed, secure, and technology-driven payment provider like PayCargo ensures that all payments remain compliant, fraud-proof, and seamlessly processed—keeping your business protected while optimizing cash flow. The expert logistician should have answered these questions: is your payment provider licensed? Are your transactions protected against fraud and compliance risks? If the answer is uncertain, now is the time to reassess the payment strategy.
     The risk to your business is too great. Follow the link to schedule a review today!
     We end this piece of fundamental information proving the following PayCargo Cameo
What Happens if your Provider is Non-Compliant?
     Imagine this: a month’s worth of payments are suddenly frozen due to your provider’s regulatory violations. Your business is now in a cash flow crisis, unable to pay vendors, carriers, or employees. Worse, regulators audit your business for using an unlicensed provider, putting you at risk of legal action and potential reputational harm.
How PayCargo Protects your Business
     Unlike unreliable providers, PayCargo is built on a foundation of financial security, compliance, and trust. Our approach ensures full compliance with money transmission laws and financial best practices, globally. Our payment process is designed to keep your funds secure, never leaving the federal banking system or commingling with other clients' money. We maintain strict compliance standards, including third-party validated SOC 1 certification, to protect your business.
In summary, PayCargo is your Trusted Partner:
        Full Regulatory Compliance – We are licensed or legally exempt in every jurisdiction where we operate, reducing your exposure to regulatory risks.
        Strict Fund Protection – Your money never leaves the federal banking system and is never commingled, ensuring full financial integrity.
        SOC 1 & Third-Party Audited Security – Regular independent audits guarantee strong financial controls and compliance standards.
        Reliable & Transparent Payment Processing – Payments are delivered on time, ensuring smooth business operations with no hidden financial risks.
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