Banks often serve as the backbones of PPS such as credit, debit, and prepaid schemes without serving as the administrator or governing body of the scheme. In these situations, banks provide their reputation, stability, ability to hold deposits, and access to national payment systems while program administrators actually manage the movement of funds throughout the scheme. Because program operators have more direct contact with customers and more insights into the movement of funds, banks involved in these schemes often outsource CDD and other elements of the AML/CFT program to the program operators. But as banks continue to be exposed to funds involved in the program, they remain responsible for implementing an effective and compliant AML/CFT program, even if transactions flow through third parties that may or may not be subject to AML/CFT requirements. LFIs should therefore adopt policies to mitigate risks arising from reliance on outside service providers, including ones that operate in high-risk countries. Where roles and responsibilities are not clearly assigned, or where the program administrator does not implement an effective program, illicit actors can exploit the cracks in the program, and the bank and the program operator together will likely be less effective than if either party were operating alone. In such cases, LFIs should maintain a contingency arrangement as necessary.