FinCEN Issues Guidance On The Prepaid Access Final Rule

Last week, the Financial Crimes Enforcement Network ("FinCEN") issued guidance in the form of frequently asked questions ("FAQs") to clarify various aspects of its final rule regarding "prepaid access" ("Final Rule").

Following the issuance of the Final Rule, which amended the Bank Secrecy Act ("BSA") regulations applicable to Money Services Businesses ("MSB") with respect to "prepaid access," financial institutions, retailers and others have had questions regarding their compliance obligations under the Final Rule.

The mandatory compliance date for the majority of the Final Rule is March 31, 2012. The FAQs can be accessed at http://www.fincen.gov/news_room/nr/html/20111102.html . In addition, FinCEN will hold a webinar today, November 9, 2011 at 3:00 PM EST, to discuss the Final Rule, the FAQs and FinCEN's regulatory expectations. More information about the webinar can be found at http://www.fincen.gov/whatsnew/html/20111102.html .