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Table of Contents

Lead Story

Doing business in the mobile channel

Patti Murphy
The Takoma Group


Industry Update

Security standards lifecycle extended

Congress approves interchange regulation amendment

New ACH rules in step with Check 21

ETA unveils new logo

Trade Association News


GS Advisory Board:
Merchant retention, taking the initiative - Part 1

Selling Prepaid

Prepaid in brief

FinCEN seeks comprehensive AML framework

Prepaid largely spared in final Durbin Amendment


Strong relationship skills obliterate obstacles

Jeffrey Shavitz
Charge Card Systems Inc.


Street SmartsSM:
Should an industry attorney review your contracts?

Ken Musante
Eureka Payments LLC

Managing your most important asset

Jeff Fortney
Clearent LLC

De-commoditize continuously to conquer a crowded market

Daniel Burrus
Burrus Research Associates Inc.

Building a PCI program that works

Tim Cranny
Panoptic Security Inc.

Digital reputation management

Peggy Bekavac Olson
Strategic Marketing

Company Profile

ROAM Data Inc.

New Products

Loyalty program, in spades

GoMo Wallet
Gold Mobile, Telcordia Technologies Inc.

Cordless retrofit for dial-up

Nebo Wireless
Nebo Wireless LLC


Turn negative thoughts into positive action



Resource Guide


A Bigger Thing

The Green Sheet Online Edition

July 12, 2010  •  Issue 10:07:01

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FinCEN seeks comprehensive AML framework

The Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, proposed new rules designed to provide guidelines for financial services businesses to follow in the reporting of possible instances of terrorist financing, money laundering and other electronically based financial crimes.

The Notice of Proposed Rulemaking (NPRM), mandated under the Credit Card Accountability Responsibility and Disclosure Act of 2009 and entitled Amendment to the Bank Secrecy Act Regulations - Definitions and Other Regulations Relating to Prepaid Access, covers prepaid cards and devices that facilitate prepaid card transactions, such as mobile phones and key fobs.

Proposed changes

FinCEN wants to rename "stored-value" - the catchall term for prepaid accounts where funds are loaded and stored for future use - as "prepaid access." FinCEN said the name change is not intended to redefine the parameters of prepaid cards and other instruments, but to "allow for future changes in technology and prepaid devices."

In addition, FinCEN proposes to substitute the terms "issuer" and "redeemer" for "provider" and "seller," respectively, because the latter terms are "not useful as the primary focal point for our regulatory efforts."

FinCEN also wants to place registration requirements on prepaid card providers in order to enhance suspicious activity reporting, customer information keeping and transactional recordkeeping. Furthermore, the bureau plans to exempt from the regulations some types of prepaid cards and services that pose lower risks of being exploited for money laundering and terrorist financing.


According to FinCEN, the proposed regulations are intended to shore up regulatory gaps that have arisen due to the growth of the prepaid card industry in the last decade, creating a regulatory environment in which new products and innovations are not addressed.

"If these gaps are not addressed, there is increased potential for the abuse of prepaid access as a means of furthering money laundering, terrorist financing and other illicit transactions through the financial system," FinCEN said.

FinCEN added that it is attempting to strike a balance between regulatory oversight "without impeding continued development of the industry." For more information on FinCEN's directives concerning the prepaid card industry and anti-money-laundering efforts, read "What is stored-value?" in the Oct. 16, 2009, edition of SellingPrepaid E-Magazine.

To view FinCEN's NPRM, go to

For more stories from SellingPrepaid E-Magazine, as well as breaking news and forums devoted to the prepaid sphere, please visit

Notice to readers: These are archived articles. Contact names or information may be out of date. We regret any inconvenience.

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