Publications

Addressing Your Prepaid Business' Most Significant Challenges under FinCEN's NPRM

July 2010
Paybefore Update

In the Notice of Proposed Rulemaking (NPRM) entitled Amendment to the Bank Secrecy Act Regulations—Definitions and Other Regulations Relating to Prepaid Access, the Financial Crimes Enforcement Network (FinCEN) proposed new rules that would amend current Bank Secrecy Act (BSA) regulations for money services businesses (MSBs). These rules would significantly expand the anti-money laundering (AML) obligations of certain parties engaged in providing prepaid products and services (excluding banks) and materially change how stored value programs and participants are defined.