2011-11-02
The Financial Crimes Enforcement Network issued FAQs to provide interpretive guidance for its July 2011 Final Rule imposing Bank Secrecy Act requirements on prepaid access providers and sellers. The rule mandates that covered entities file suspicious activity reports, maintain anti-money laundering programs, and collect customer and transactional information. It defines covered prepaid programs while excluding certain low-risk arrangements and clarifying the regulatory status of retailers, reloaders, and banks.