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Google does not provide those products (not in the US, as far as I am aware), but they are a money transmitter in the same vein as Square/Block, Stripe, and Venmo [0]. They won't be directly subject to the Bank Secrecy Act, but they partner with the major payment networks (who have their own rules and their own partner programs with banks) as part of Google Pay and customer payment profiles.

But I don't think this matters much for this case, as DHS is not investigating financial crimes. This is about what discretion Google has to comply with administrative warrants, which is not settled law and isn't clearly spelled out in their own policy.

0: https://support.google.com/googlepay/answer/7160765?hl=en

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I just looked it up, and money transmitters are included in the Banking Secrecy Act as "Money Services Businesses". So yes, they have KYC obligations in the sense that they know where you are moving your money and are obligated to tell investigators.

Unfortunately, KYC is used for much more than just financial crimes, and the precedent to comply is much more firmly established.

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