Kill Bitcoins ~ Next, Prepaid Gift Cards
Posted: Wed May 15, 2013 8:01 pmThe estimated amount of money laundered globally in one year is 2 - 5% of global GDP, or $800 billion - $2 trillion in current US dollars. Though the margin between those figures is huge, even the lower estimate underlines the seriousness of the problem governments have pledged to address.
After the kill Bitcoins they will ramp up the efforts on prepaid gift cards.
Dated information but still a good read....It is all about following the money!
April 12, 2012
Dear Valued Customer:
On July 29, 2011, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued new anti-money laundering rules that in a very extreme instance may likely affect your location(s). These rules govern "prepaid access" and are designed to regulate the use of prepaid products (including "retail" closed-loop gift cards) so as to prevent money-laundering activities.
FinCEN has announced that it will begin enforcing these rules immediately, so all gift card merchants are being notified this week, though to be honest with you we have evaluated all clients in our database and don't believe any single one would have broached these new rules at any time since inception. Nevertheless we feel inclined to ensure everyone is apprised of the newly implemented rules.
All merchants who issue their own gift cards (either directly or through a third-party vendor) and merchants who sell or reload other company's gift cards are impacted by the rules. This would include closed-loop gift cards that we are involved with as well as "open loop" prepaid gift cards as you might see in a mall or grocery store being sold with the ATM network and/or Visa or MasterCard or American Express logo's, of which Secure Payment Systems is not currently involved in.
Your primary obligations are the following to be exempt from FinCEN SAR reporting:
1.You may not load more than $2,000 of value onto a single prepaid gift card in any given day.
2.You may not load more than $10,000 of value onto multiple prepaid gift cards for a single consumer in any given day.
3.You may not load value onto a card causing the sum of (a) the beginning card daily balance and (b) all balance increases of that same day for that same card to exceed $2,000
To reiterate, we've not encountered any transactions like this in our history, but to be honest there is no way for us to determine that item # 2 has ever been breached (given we do not see consumer identification during a gift card purchase), other than to note that historically we've never seen $10,000 activated or increased in any one day from any one location.
Note (1): If you do not already have an activation or balance increase daily limit set that is lower than the $2,000 value we will implement that change effective immediately per location and issue a response of "Exceeds Load Max" to the terminal or retail POS system if the exception is triggered.
Note (2): If item # 2 above applies to your location then it is your responsibility to follow the new reporting requirements associated with the anti-money laundering regulation. In summary, you will need to collect demographic information from the customer, the card number being issued, as well as transactional information on a downloadable SAR 109 (Suspicious Activity Report: http://fincen.gov/forms/files/fin109_sarmsb.pdf) document issued by the U.S. Treasury Department and to be remitted directly to FinCEN.
Note (3): In order to comply with item 3 above we will implement that change effective immediately per location and issue a response of "Exceeds Load Max" to the terminal or POS system if the exception is triggered.
Though the primary focus of the new ruling is to regulate "open-loop" network branded prepaid cards such as prepaid ATM cards and prepaid Visa/MC/Amex cards, the traditional "closed loop" retail cards were also ensnared to some degree despite the very limited number of transactions that might actually breach these new rules.
If you have specific questions you may contact FinCEN's regulatory helpline at 1.800.949.2732., or if you are interested, the entire ruling can be found at http://www.gpo.gov/fdsys/pkg/FR-2011-07 ... -19116.pdf.
Thank You,
Secure Payment Systems
Source: http://securepaymentsystems.com/press/f ... uling.html
A Quick Reference Guide for Money Services Businesses
Financial Crimes Enforcement Network
U.S. Department of the Treasury
Washington, DC
The Bank Secrecy Act
The Bank Secrecy Act (BSA) was enacted by Congress in 1970 to fight money laundering and other financial crimes.
The BSA requires many financial institutions to create “paper trails” by keeping records and filing reports on certain transactions. These reports are submitted to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). FinCEN collects and analyzes the information to support law enforcement investigative efforts and to provide U.S. policy makers with strategic analyses of domestic worldwide money laundering developments, trends and patterns.
The BSA’s reporting and recordkeeping provisions apply to banks, savings and loans, and credit unions as well as other financial institutions, including money services businesses (MSBs).
In addition to the general guidelines provided here, other BSA requirements may apply to a specific MSB. Please visit www.msb.gov for more regulatory information.
For further information, see our pamphlet entitled “Reporting Suspicious Activity: A Quick Reference Guide for Money Services Businesses.”
Recordkeeping Requirements
Currency Transaction Reports
MSBs must file a Currency Transaction Report (CTR) within 15 days whenever a transaction or series of transactions in currency:
Involves more than $10,000 in either cash-in or cash-out, and
Is conducted by, or on behalf of, the same person, and
Is conducted on the same business day.
Multiple cash transactions are considered to be one transaction on which a CTR must be filed if the MSB has knowledge that:
They are by or on behalf of the same customer during one business day, and
They are conducted at one or more branches or agents of the same MSB, and
They total more than $10,000 in either cash-in or cash-out.
How to File a CTR
1. Verify and record customer ID.
2. Record customer transaction information.
3. Make a copy of the completed CTR.
4. Send the original CTR to:
IRS Detroit Computing Center
Attn: CTR
P.O. Box 33604
Detroit, MI 48232-5604
5. Keep a copy of the CTR for 5 years from the date of filing the report.
Cash Purchases of $3,000-$10,000, Inclusive
MSBs that sell money orders or traveler’s checks are required to record cash purchases involving $3,000- $10,000, inclusive.
Multiple cash purchases of monetary instruments totalling $3,000 or more must be treated as one purchase which must be recorded if:
1. They are made at the same time, or
2. The MSB has knowledge that such purchases occurred during one business day.
How to record a money order or traveler’s check sale for cash of $3,000-$10,000, inclusive:
1. Verify and record customer information, including ID.
2. Record transaction information – amount, date of sale and serial number(s) for each instrument.
3. Keep the record for 5 years from the date of transaction.
Money Transfers of $3,000 or More
MSBs that provide money transfer services must obtain and record specific information for each money transfer of $3,000 or more, regardless of the method of payment.
How to record a money transfer of $3,000 or more for money transfer senders and receivers:
1. Verify customer ID.
2. Record customer and transaction information.
3. Sender must provide certain information to the receiving MSB or other receiving financial institution.
4. Keep the record for 5 years from the date of transaction.
Currency Exchanges of More Than $1,000
Currency exchangers must keep a record of each exchange totaling more than $1,000 in either domestic or foreign currency.
How to record a currency exchange:
1. Record customer information.
2. Record transaction information.
3. Keep the record for 5 years from the date of transaction.
Suspicious Activity Reporting Requirements
Certain money services businesses – businesses that provide money transfers or currency dealing or exchange; or businesses that issue, sell, or redeem money orders or traveler’s checks – must report suspicious activity involving any transaction or pattern of transactions at or above a certain amount:
$2,000 or more;
$5,000 or more for issuers reviewing clearance records.
You have 30 calendar days to file a SAR after becoming aware of any suspicious transaction that is required to be reported.
How to Report Suspicious Activity
1. Record relevant information on a Suspicious Activity Report by MSB (SAR-MSB) form available at www.msb.gov or by calling the IRS Forms Distribution Center: 1-800-829-3676.
2. Submit completed SAR to:
Detroit Computing Center
Attn: SAR-MSB
P.O. Box 33117
Detroit, MI 48232-5980.
3. Keep a copy of the report and any supporting documentation for 5 years from the date of filing the report.
Summary of BSA Requirements for MSBs
Registration – Certain MSBs must register and maintain a list of agents, if any.
If an MSB knows, suspects, or has reason to suspect that any transaction or activity is suspicious and it involves or aggregates funds or other assets of $2,000 or more, ($5,000 or more if identified by issuers from a review of clearance records), it must file a SAR.
Anti-Money Laundering (AML) compliance program – All MSBs are required to develop and implement an AML compliance program.
If an MSB provides either cash-in or cash-out transactions of more than $10,000 with the same customer in a day, it must file a CTR.
If an MSB provides money orders or traveler’s checks for cash of $3,000-$10,000, inclusive, to the same customer in a day, it must keep a record.
If an MSB provides money transfers of $3,000 or more to the same customer in a day, regardless of the method of payment, it must keep a record.
If an MSB provides currency exchanges of more than $1,000 to the same customer in a day, it must keep a record.
For answers to your questions about BSA reporting and recordkeeping requirements, please visit www.msb.gov.
Or call:
Detroit Computing Center Hotline
1-800-800-2877
FinCEN Regulatory Helpline
1-800-949-2732
To order free guidance materials
1-800-386-6329
To order BSA forms from the
IRS Forms Distribution Center
1-800-829-3676
After the kill Bitcoins they will ramp up the efforts on prepaid gift cards.
Dated information but still a good read....It is all about following the money!
April 12, 2012
Dear Valued Customer:
On July 29, 2011, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued new anti-money laundering rules that in a very extreme instance may likely affect your location(s). These rules govern "prepaid access" and are designed to regulate the use of prepaid products (including "retail" closed-loop gift cards) so as to prevent money-laundering activities.
FinCEN has announced that it will begin enforcing these rules immediately, so all gift card merchants are being notified this week, though to be honest with you we have evaluated all clients in our database and don't believe any single one would have broached these new rules at any time since inception. Nevertheless we feel inclined to ensure everyone is apprised of the newly implemented rules.
All merchants who issue their own gift cards (either directly or through a third-party vendor) and merchants who sell or reload other company's gift cards are impacted by the rules. This would include closed-loop gift cards that we are involved with as well as "open loop" prepaid gift cards as you might see in a mall or grocery store being sold with the ATM network and/or Visa or MasterCard or American Express logo's, of which Secure Payment Systems is not currently involved in.
Your primary obligations are the following to be exempt from FinCEN SAR reporting:
1.You may not load more than $2,000 of value onto a single prepaid gift card in any given day.
2.You may not load more than $10,000 of value onto multiple prepaid gift cards for a single consumer in any given day.
3.You may not load value onto a card causing the sum of (a) the beginning card daily balance and (b) all balance increases of that same day for that same card to exceed $2,000
To reiterate, we've not encountered any transactions like this in our history, but to be honest there is no way for us to determine that item # 2 has ever been breached (given we do not see consumer identification during a gift card purchase), other than to note that historically we've never seen $10,000 activated or increased in any one day from any one location.
Note (1): If you do not already have an activation or balance increase daily limit set that is lower than the $2,000 value we will implement that change effective immediately per location and issue a response of "Exceeds Load Max" to the terminal or retail POS system if the exception is triggered.
Note (2): If item # 2 above applies to your location then it is your responsibility to follow the new reporting requirements associated with the anti-money laundering regulation. In summary, you will need to collect demographic information from the customer, the card number being issued, as well as transactional information on a downloadable SAR 109 (Suspicious Activity Report: http://fincen.gov/forms/files/fin109_sarmsb.pdf) document issued by the U.S. Treasury Department and to be remitted directly to FinCEN.
Note (3): In order to comply with item 3 above we will implement that change effective immediately per location and issue a response of "Exceeds Load Max" to the terminal or POS system if the exception is triggered.
Though the primary focus of the new ruling is to regulate "open-loop" network branded prepaid cards such as prepaid ATM cards and prepaid Visa/MC/Amex cards, the traditional "closed loop" retail cards were also ensnared to some degree despite the very limited number of transactions that might actually breach these new rules.
If you have specific questions you may contact FinCEN's regulatory helpline at 1.800.949.2732., or if you are interested, the entire ruling can be found at http://www.gpo.gov/fdsys/pkg/FR-2011-07 ... -19116.pdf.
Thank You,
Secure Payment Systems
Source: http://securepaymentsystems.com/press/f ... uling.html
A Quick Reference Guide for Money Services Businesses
Financial Crimes Enforcement Network
U.S. Department of the Treasury
Washington, DC
The Bank Secrecy Act
The Bank Secrecy Act (BSA) was enacted by Congress in 1970 to fight money laundering and other financial crimes.
The BSA requires many financial institutions to create “paper trails” by keeping records and filing reports on certain transactions. These reports are submitted to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). FinCEN collects and analyzes the information to support law enforcement investigative efforts and to provide U.S. policy makers with strategic analyses of domestic worldwide money laundering developments, trends and patterns.
The BSA’s reporting and recordkeeping provisions apply to banks, savings and loans, and credit unions as well as other financial institutions, including money services businesses (MSBs).
In addition to the general guidelines provided here, other BSA requirements may apply to a specific MSB. Please visit www.msb.gov for more regulatory information.
For further information, see our pamphlet entitled “Reporting Suspicious Activity: A Quick Reference Guide for Money Services Businesses.”
Recordkeeping Requirements
Currency Transaction Reports
MSBs must file a Currency Transaction Report (CTR) within 15 days whenever a transaction or series of transactions in currency:
Involves more than $10,000 in either cash-in or cash-out, and
Is conducted by, or on behalf of, the same person, and
Is conducted on the same business day.
Multiple cash transactions are considered to be one transaction on which a CTR must be filed if the MSB has knowledge that:
They are by or on behalf of the same customer during one business day, and
They are conducted at one or more branches or agents of the same MSB, and
They total more than $10,000 in either cash-in or cash-out.
How to File a CTR
1. Verify and record customer ID.
2. Record customer transaction information.
3. Make a copy of the completed CTR.
4. Send the original CTR to:
IRS Detroit Computing Center
Attn: CTR
P.O. Box 33604
Detroit, MI 48232-5604
5. Keep a copy of the CTR for 5 years from the date of filing the report.
Cash Purchases of $3,000-$10,000, Inclusive
MSBs that sell money orders or traveler’s checks are required to record cash purchases involving $3,000- $10,000, inclusive.
Multiple cash purchases of monetary instruments totalling $3,000 or more must be treated as one purchase which must be recorded if:
1. They are made at the same time, or
2. The MSB has knowledge that such purchases occurred during one business day.
How to record a money order or traveler’s check sale for cash of $3,000-$10,000, inclusive:
1. Verify and record customer information, including ID.
2. Record transaction information – amount, date of sale and serial number(s) for each instrument.
3. Keep the record for 5 years from the date of transaction.
Money Transfers of $3,000 or More
MSBs that provide money transfer services must obtain and record specific information for each money transfer of $3,000 or more, regardless of the method of payment.
How to record a money transfer of $3,000 or more for money transfer senders and receivers:
1. Verify customer ID.
2. Record customer and transaction information.
3. Sender must provide certain information to the receiving MSB or other receiving financial institution.
4. Keep the record for 5 years from the date of transaction.
Currency Exchanges of More Than $1,000
Currency exchangers must keep a record of each exchange totaling more than $1,000 in either domestic or foreign currency.
How to record a currency exchange:
1. Record customer information.
2. Record transaction information.
3. Keep the record for 5 years from the date of transaction.
Suspicious Activity Reporting Requirements
Certain money services businesses – businesses that provide money transfers or currency dealing or exchange; or businesses that issue, sell, or redeem money orders or traveler’s checks – must report suspicious activity involving any transaction or pattern of transactions at or above a certain amount:
$2,000 or more;
$5,000 or more for issuers reviewing clearance records.
You have 30 calendar days to file a SAR after becoming aware of any suspicious transaction that is required to be reported.
How to Report Suspicious Activity
1. Record relevant information on a Suspicious Activity Report by MSB (SAR-MSB) form available at www.msb.gov or by calling the IRS Forms Distribution Center: 1-800-829-3676.
2. Submit completed SAR to:
Detroit Computing Center
Attn: SAR-MSB
P.O. Box 33117
Detroit, MI 48232-5980.
3. Keep a copy of the report and any supporting documentation for 5 years from the date of filing the report.
Summary of BSA Requirements for MSBs
Registration – Certain MSBs must register and maintain a list of agents, if any.
If an MSB knows, suspects, or has reason to suspect that any transaction or activity is suspicious and it involves or aggregates funds or other assets of $2,000 or more, ($5,000 or more if identified by issuers from a review of clearance records), it must file a SAR.
Anti-Money Laundering (AML) compliance program – All MSBs are required to develop and implement an AML compliance program.
If an MSB provides either cash-in or cash-out transactions of more than $10,000 with the same customer in a day, it must file a CTR.
If an MSB provides money orders or traveler’s checks for cash of $3,000-$10,000, inclusive, to the same customer in a day, it must keep a record.
If an MSB provides money transfers of $3,000 or more to the same customer in a day, regardless of the method of payment, it must keep a record.
If an MSB provides currency exchanges of more than $1,000 to the same customer in a day, it must keep a record.
For answers to your questions about BSA reporting and recordkeeping requirements, please visit www.msb.gov.
Or call:
Detroit Computing Center Hotline
1-800-800-2877
FinCEN Regulatory Helpline
1-800-949-2732
To order free guidance materials
1-800-386-6329
To order BSA forms from the
IRS Forms Distribution Center
1-800-829-3676
Don't tell Hoard that all his huge zinc dumps have been recorded! 
But everyone knew that already....