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Bryan Cave Hosts ACAMS Atlanta Chapter Prepaid Access Event

Bryan Cave is hosting the quarterly CPE and general membership meeting for the Atlanta Chapter of the Association of Certified Anti-Money Laundering Specialists on Thursday, November 3, 2011, from 10:00am to 12:00pm.  We are also very pleased to announce that our own Judie Rinearson will be the guest speaker.

All AML/CTF professionals in the region are welcome to attend.

November 3, 2011
10:00 AM – 12:00 PM

Fourteenth Floor
1201 W. Peachtree Street, NW
Atlanta, GA 30309

Free for Chapter Members; $5 for Non-Chapter Members

RSVP Here

Judith Rinearson leads the payments practice team for Bryan Cave LLP, where she is a partner in the firm’s New York City office. She also is chair of the Network Branded Prepaid Card Association’s Government Relations Working Group, the association’s representative to FinCEN’s Bank Secrecy Act Advisory Group and a Paybefore contributing editor.

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FinCEN Issues Final Rule on Prepaid Access

Retailers Issuing Gift Cards and/or Selling Other
Companies’ Gift Card or Prepaid Cards Impacted

New anti-money laundering regulations that directly impact retail businesses that issue or sell gift cards or other prepaid cards have recently been released. These new regulations, known as the prepaid access “Final Rule,” currently effective on September 27, 2011, were issued by the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) and require the collection and verification of customer information when certain prepaid cards are sold or reloaded. Retailers issuing their own closed loop gift cards, or selling and reloading other companies’ open and/or closed loop gift cards may be significantly impacted by the new Final Rule. (Print-Friendly Version)

I. RETAILERS THAT ISSUE THEIR OWN “CLOSED LOOP” GIFT CARDS

Many retailers now issue (either directly or through a gift card company) their own gift cards useable solely to buy goods or services at their own locations. Such programs have in the past been deemed low risk. However, the new Final Rule may impact such programs depending on how such gift cards are sold and structured.

What is Closed Loop Prepaid Access?

Under the new Final Rule, “closed loop prepaid access,” is defined as “[p]repaid access to funds or the value of funds that can be used only for goods or services in transactions involving a defined merchant or location (or set of locations).” The definition includes gift cards that provide access to a specific retailer, affiliated retailers, or retail chain, or alternatively, a designated locale, such as a college campus, or a subway system.

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