• The Financial Crimes Enforcement Network Issues Notice of Proposed Rulemaking to Establish More Comprehensive Regulatory Framework for Non-bank Prepaid Access
  • July 1, 2010 | Authors: Andres A. Fernandez; Marina Olman; Clemente L. Vázquez-Bello
  • Law Firm: Gunster, Yoakley & Stewart, P.A. - Miami Office
  • On June 21, 2010, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“Notice”) proposing to revise the Bank Secrecy Act (“BSA”) with regard to stored value or prepaid access. The proposed changes are intended to address regulatory gaps that have resulted from the proliferation of prepaid innovations over the last ten (10) years and their increasing use as an accepted payment method.