Regulatory Alerts2016-03-24
Frequently Asked Questions regarding Prepaid Access
The Financial Crimes Enforcement Network (FinCEN) issued this guidance to clarify regulatory requirements for prepaid access under the Bank Secrecy Act. The document confirms that retailers may use a uniform de minimis refund threshold based on the highest state requirement and extends the closed-loop exclusion to technology-driven payment systems like QR codes. Additionally, FinCEN specifies that policies to avoid seller designation must be risk-based rather than strictly requiring universal customer identification, and clarifies that providers must only list entities meeting the specific definition of a seller on their MSB agent lists.
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