Assessing Treasury's 'Prepaid Access' Rule

Law360, New York (August 3, 2011, 8:38 PM EDT) -- On July 27, 2011, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) released its much-anticipated final rule applying the anti-money laundering requirements of the Bank Secrecy Act to certain open- and closed-loop prepaid payment products in a comprehensive manner for the first time.

The final rule redefines “stored value” as “prepaid access” and imposes significant regulatory obligations on both “providers” and “sellers” of “prepaid access,” including certain anti-money laundering program, reporting and recordkeeping requirements.

Notably, in response to public comment, the final rule significantly enlarges the...
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