Abstract
Those operating in the payments space must address a variety of legal and practical constraints. Legal divergence within the United States presents new challenges for compliance obligations, including CDD and monitoring duties. State efforts to legalize marijuana, state and federal efforts to address the legal status of gambling operations in the Internet environment, and money laundering dangers from transactions in the bitcoin environment each present compliance challenges. This program will provide insights and examples concerning how legal constraints affect decisions to restrict the scope of the payments network (winnowing) to avoid legal and business risks from participation (the shadows)