FinCEN's Prepaid Access Rule.

Mondaq Business Briefing › Nbr. 2011, January 2011

Position:: FinaDepartment of the Treasury. Financial Crimes Enforcement Network

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FinaDepartment of the Treasury. Financial Crimes Enforcement Network

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FinCEN's Prepaid Access Rule.

On July 29, 2011, the Financial Crimes Enforcement Network ("FinCEN") published a final rule to amend the Bank Secrecy Act ("BSA") regulations applicable to Money Services Businesses ("MSB") with respect to stored value or "prepaid access" ("Final Rule" or "Rule").1 The Rule's effective date is September 27, 2011. The compliance deadline for 31 C.F.R. s. 1022.380 (registration of money services businesses) is January 29, 2012.

COVERAGE OF "PREPAID PROGRAMS"

Section 1010.100(ff)(4)(iii) defines a "prepaid program" as an "arrangement under which one or more persons acting together provide(s) prepaid access." Under the Rule, "prepa...

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