Operation Choke Point has received a significant amount of criticism, which reached a head after a financial services trade association moved to sue federal bank regulators, accusing the agencies of improperly issuing and enforcing new policies that prevent banks from handling transactions for payday lenders and other ‘high risk’ online merchants. Allyson B. Baker and Thomas E. Gilbertsen of Venable LLP, analyse the concerns and the extent to which a party can be held liable for another’s conduct.
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