Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

Take On Payments

January 28, 2013

Do GPR Prepaid Cards Pose Significant Money Laundering Threats?

When it comes to laundering proceeds from illicit activities, criminals have historically had a number of financial instruments and methodologies at their disposal. These choices have ranged from payment products tied to demand deposit accounts such as checks, wires, and debit/ATM card transactions to money transfers via money transmitters. The birth of general purpose reloadable (GPR) prepaid cards in the early 1990s created yet another payment instrument that could potentially be used to clean dirty money.

Although no payment instrument—GPR prepaid cards included—is completely immune to money laundering, the payments industry can adopt risk measures to mitigate the attractiveness of these cards to criminals. But what makes a payment choice attractive to money launderers? Criminals generally seek the fastest method to move their ill-gotten proceeds the furthest away from their illegal activities. Ultimately, they want to distance themselves and their financial gain from the crime in the quickest way possible. Anonymity, accessibility, immediate liquidity, and transportability of funds are all payment characteristics that a money launderer finds attractive.

The Retail Payments Risk Forum dove into the regulatory environment and risk management practice of the GPR prepaid card industry, and wrote up findings in a paper available on the Atlanta Fed's website. Among the paper's findings is that, as GPR prepaid cards have grown in popularity and come under increased scrutiny by regulators, significant regulatory measures and industry-wide adopted practices have greatly reduced, but not eliminated, their money laundering risks. And while U.S. regulators and the card industry have made great strides with anti-money laundering measures, GPR prepaid cards issued internationally do not necessarily face the same stringent risk environment, so they pose significant money laundering risks.


For more details on the money laundering risk environment for GPR prepaid cards, read the paper.

Douglas A. KingBy Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

January 28, 2013 in fraud, money laundering, prepaid | Permalink


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Interesting paper. The DoJ paper and rebuttal go into greater depth on the actual risks of GPR's in money laundering.

GPR's are not really like any other financial tool. Most are tied to a bank DDA with explicit account opening procedures.

What would be interesting is an analysis of recent GPR innovations which allow individuals "deposit-only" capability. Basically these are simple pieces of plastic that allow ground level drug dealers to deposit cash sales into a master account any where in the country.

Of course, it could be a parent funding a child.

Posted by: CMS | January 28, 2013 at 09:31 AM

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November 13, 2012

The Rule of 3, or Desperately Seeking Payment Products

Generally speaking, I have always believed in the "Rule of 3." When you're looking for something new—with your home, for example, or with your clothing style—try out three, and the obvious will likely emerge as a winner. When I had my design business and helped people pick products out for their homes, I never presented them with more than three options for any one product. If I did, sure enough they would get frustrated and become unlikely to make a confident decision.

When I changed career paths here at the Fed and entered the world of retail payments, I decided to look into some new payment products and services for my children. I am the mother of teenagers who are always asking for money, so my first goal was to provide them with a safe, easy, and secure way to have and spend money.

I began to research some products, and narrowed my choices down to three options to explore: gift cards, prepaid debit cards, and bank-issued debit cards. Immediately, I eliminated gift cards, which once depleted are usually not reloadable. I wanted this to be a lifestyle change, something that could be extended; therefore, I focused my research on option number 2, reloadable cards. I started at a local grocery store, where I stood looking in awe at the tower of choices I had before me. Most cards here cost $4.95 before you load money on them. A store clerk told me that a big-box retailer had the same products for $3, so off I went.

prepaid card display The first purchase was for my son. At the checkout, I asked the clerk to load $40 on the card. The clerk informed me that I could not use my credit card to fund a prepaid card—I needed cash, or a preprinted payroll or government check, or direct deposit from my paycheck, or a standard transfer from my bank that could take up to 13 days—and then I would be charged a fee.

This did not seem very user-friendly, especially since I do not carry an ATM card, nor do I frequent this big-box retailer often. But I was determined to try this new payment method, so I returned the next day and paid $3 to buy a $40 card. (I now know that this $3 fee is waived if you get your card online and that there is a reload fee of $3 and a monthly maintenance fee of $3.) This still seemed like a better option than a bank debit card. I registered the card online for my son (required for activation) and entered personal information like name, address, and social security number. I was not thrilled with that level of privacy loss—however, as the small print explained, "Federal law requires us to obtain, verify, and record information that identifies you when you open up this account." In addition, this is the only way I could get a refund if the card were lost or stolen, and that was one of my three preliminary requirements.

So I started looking for the actual custom card in the mail with my son's name on it. I waited two weeks—and no card. I reviewed the fine print included inside the package to discover that you must be over the age of 16 to buy and use this kind of card. This information was printed nowhere on the outside of the packaging. My son is 15, not even 16 yet. So, there will not be a custom card coming in the mail, and this temporary card I have will become useless once the balance falls to zero. Have I mentioned that there is a $3 monthly maintenance fee that applies after the tenth day you have the card? So far, I have paid $6 to lend him $40 on a card that is not reloadable.

This led me to option number 3, my bank, where I learned about student accounts that don't charge for bank-issued debit cards. And, for convenience, I can transfer funds from my checking account into the student account, which funds the debit card. Honestly, this was not my first choice, but it emerged as the safest, cheapest, and most convenient. I decided to use this opportunity to teach my kids about online banking, overdraft fees (because I am not linking the student account to my account), the importance of passwords, and balancing their (virtual) checkbooks.

This account has proven to be a wonderful tool, and my kids now look forward to logging in and checking their balances and confirming that their "payday" has been deposited upon completion of their agreed-upon chores. I can't wait to discover more opportunities of my new job here in the Forum!

Michelle CastellBy Michelle Castell, senior payments risk analyst in the Retail Payments Risk Forum at the Atlanta Fed

November 13, 2012 in cards, prepaid | Permalink


I am surprised that you did not come across the prepaid "teen" card offerings such as Visa Buxx, which is a prepaid card specifically designed for parents with teenagers who would like to provide their child with a bank account type of relationship. The beauty of the teen card is that there are 2 account holders and one card holder. The parent has total visibility on the account and can load funds (without a fee from a checking account) from any source, even limit where the card is used and look at the account activity. The teen, can use the card anytime any place and also monitor statements on line. This product has become very popular with high school and college students and it has all the safety and security of a DDA account without having to keep a minimum balance or having the risk of over drafting the account. It is definitely worth looking into.

Posted by: Madeline K. Aufseeser | November 14, 2012 at 09:40 AM

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October 29, 2012

Crossing the Border: More Reason to Check Your Pockets

It's no secret that cross-border travel has involved a lot more restrictions since 9-11. Declaration of assets and physical inspection of luggage and other items are expected, as well as tedious and unpleasant, aspects of a vacation or business trip. That could change soon and not for the better, under a new rule proposed October 2011 by the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The new rule would require travelers to add the balances of prepaid cards to declaration reports.

While issuing such a rule sounds reasonable in theory, enforcement is likely to be another matter. Unlike checking the content of physical items, digital value stored in or accessed by a plastic card or a mobile phone is difficult to measure. How can you tell how much money is loaded on the prepaid card to validate the declared value? In fact, how will enforcement officials even distinguish prepaid cards from credit and debit?

FinCEN's proposed rulemaking expected to be final soon
FinCEN's Notice of Proposed Rule Making (NPRM), expanding the scope of its cross-border reporting requirements to include "tangible prepaid access devices," is poised to assume its final form, some expect as soon as the end of the year. Currently, travelers have to report aggregated cash and other monetary instruments exceeding $10,000. The premise behind this requirement is that it prevents money laundering and criminal-terrorist financing by enabling the traceability of currency and its equivalents, and hopefully eliminating anonymous flows of money into and out of the United States.

Previously, FinCEN issued a rule recognizing the advanced innovations in prepaid payment methods and the subsequent need to expand the definition to include all form factors backed by prepaid value, in addition to cards. That rule also changed the payment method definition from "stored value"—implying value stored digitally within the form factor—to "prepaid access," a term that more accurately describes the process for electronic retrieval of prepaid funds maintained by the payment provider.

Handheld readers at borders and airports?
According to comments published in response to the NPRM, the Department of Homeland Security is working on a "handheld reader with features that will, among other things, allow law enforcement to quickly and accurately differentiate between a traveler's debit, credit, and prepaid products…in a manner which imposes minimal to no inconvenience to individuals and complies with U.S. laws, regulations, and procedures." Furthermore, according to the comments, the enforcement challenge is not new, nor is the concept of a device or document that can be used to access value. The current challenges are similar to those presented in the past with other monetary instruments such as checks, money orders, and traveler checks.

Still keeping an eye on bulk cash
A recent study conducted by U.S. and Mexican officials reported that stored-value and prepaid cards are "potentially powerful means for both transporting and laundering money," but still found that the majority of illicit funds movement across the U.S. and Mexican border takes place in the form of bulk cash. In fact, most of the criminal movement of funds does not involve laundering, which is typically accomplished by first depositing illicit funds into a bank or business before moving it. This is particularly important in addressing criminal terrorist financing that may only involve transport. It will be important for regulators to strike a balance between proactive enforcement in addressing crime in electronic channels and effective management of more basic schemes involving the transport of cash across borders.

Many questions still remain
Many commenters to the NPRM have expressed opposition to the premise that prepaid access devices should be classified as monetary instruments since they merely access funds held at a bank or financial institution. When law enforcement takes possession of a cash or monetary instrument at the border, they are effectively holding the funds, but not so with a prepaid card or other device. Holding the card does not provide access to the underlying funds. Furthermore, the legislation is easy to evade. According to a comment from the Network Branded Prepaid Card Association, "a card can truthfully be reported as having just $1,000 on it; and then two hours later, the card can be loaded with funds from another location and have $15,000 on it."

Commenters also suggested alternatives that would focus the final-rule decision making on more effective measures, such as carrying a large number of cards, particularly if the cards are not embossed with the cardholder's name. For example, a person carrying more than 20 nonpersonalized cards would have to declare the aggregated value and be prepared to address questions by border patrol agents. Such a measure could avoid the need for high-cost readers and the potential privacy issues that may ensue if the final rule is issued as proposed.

Cynthia MerrittBy Cynthia Merritt, assistant director of the Retail Payments Risk Forum

October 29, 2012 in prepaid | Permalink


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August 13, 2012

Tourism Traffic Boosts Prepaid Cards

Prepaid cards, at least until 2010, were the fastest growing payment method in the United States, according to the Fed's latest payments study. Their use is also growing in other markets, including Latin America in general and Brazil in particular, especially for funding tourism activities. Brazilian tourists are increasingly choosing rechargeable prepaid travel cards loaded with U.S. currency over cash. Interestingly, U.S. banks are also realizing economic benefits from tourists' move from cash to prepaid cards.

Growing South Florida tourism drives Brazilians to spend more
Brazilians make up the second largest tourist group to Florida, next to Canadians (3.3 million of whom visited the United States in 2011). Last year, approximately 1.5 million Brazilians visited Florida. They spent more than a billion dollars total, with a per-visit amount typically exceeding $5,000. Altogether, the Fed Atlanta's Miami Branch paid out $1.7 billion U.S. dollars to Brazil.

A number of factors are contributing to the rise in Brazilian tourists to Florida, including the high number of available flights, expedited processing for travel visas, significantly lower prices for many designer brands coupled with the absence of Brazilian import tax, and relatively cheaper real estate prices.

Brazilian tax rule, other factors influence credit card spending abroad But why are these tourists increasing choosing to use prepaid cards? In 2011, the Brazilian government imposed a new financial operations tax of 6.38 percent on foreign transactions made with Brazilian-issued credit cards. The tax, called the IOF—short for Imposto sobre Operações Financeiras—makes using credit cards abroad very unattractive for Brazilians.

Prepaid travel cards also offer more favorable exchange rates, and they insulate consumers against rate fluctuations by offering a fixed exchange rate on all purchases.

Banks in Brazil also benefit from prepaid cards used abroad. Transportation and custody expenses make it costly for Brazil's commercial banks to obtain and hold U.S. dollars. As a result, these banks are actively promoting prepaid cards. U.S. commercial banks quickly seized the opportunity to compete with their Brazilian counterparts by rolling out marketing campaigns in Brazil promoting the benefits of prepaid travel cards for U.S. travel.

All these conditions and incentives have combined to create a 50 percent rise in travel card applications by Brazilians shortly after the tax regulation was introduced.

Brazil offers an interesting case study of the growth in the use of prepaid payment cards. Just as U.S. consumers beyond the unbanked are recognizing the ease and convenience of this payment device, so are international consumers.

Paul GrahamBy Paul Graham, assistant vice president and branch operations officer, Miami Branch of the Federal Reserve Bank of Atlanta

August 13, 2012 in banks and banking, cards, payments, prepaid | Permalink


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June 4, 2012

The new consumer protection agency looks at prepaid cards

The prepaid card industry has grown faster than many expected it to in recent years. The industry has a wide range of customers today, including not only the underbanked market but also many other market segments. In fact, in a public hearing on May 23, 2012, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray noted that while many consumers "actually have a bank account, they often use nonbank products to meet their financial needs," including the relatively new prepaid card. As this product has grown in acceptance, consumer advocacy groups have voiced concerns about the potential lack of consumer protections and the need for regulatory clarity for prepaid product providers. In response to these concerns, the CFPB announced its plan to launch a rulemaking initiative to promote safety and transparency in the prepaid market.

Why legal protections differ
While payment law critics cite the fragmented legal landscape for retail payment methods, the differences lie in the underlying mechanics. In the simplest of terms, retail payments can be segmented into three basic genres: "paying now" through a deduction in your account balance at a financial institution through either a check or debit card; "paying later" by using a credit card, which involves a loan from the payment service provider to cover the cost of the purchase in the transaction; and "paying before," by prefunding an account by the consumer for use at a later time.

These inherent funding differences lend themselves to different laws, regulations, and rule sets, since the timing and liability for maintaining the safety of the funds in each case differs. Consumer lending protection laws, for example, have relevance only for credit payment products. The emergence of new prepaid products and nonbanks participating in new business models, along with the sometimes questionable pricing schemes and fees, points to the need for industry dialogue on what new regulatory governance is needed in prepaid services today.

Growth in prepaid
The Federal Reserve’s last triennial payment study revealed that prepaid cards, particularly the general-purpose reloadable (GPR) variety, were the fastest growing retail payment in recent years, even though they represent a relatively small piece of the overall pie of preferred retail payment types. GPR cards allow the consumer—or another party, like an employer—to add funds to the card. This reloadable feature makes the product functional and convenient, and allows consumers who traditionally relied on cash to participate in the electronic economy.

Recent growth in prepaid cards

Increased e-commerce is in turn leading to the use of prepaid in the mobile environment. Payment providers have been experimenting in recent years with bridge technologies such as prepaid card stickers using contactless technology. The sticker is put on the mobile handset, and is intended to influence consumer payment behavior by offering consumers the opportunity to tap their mobile phones at the merchant’s point of sale. As a result, the advanced notice of rulemaking notes that a prepaid "card" may also take the form of other access devices, such as key fobs, or even a cell phone application that accesses a prepaid financial account.

What the CFPB is offering consumers
When it comes to prepaid cards, the public hearing made it clear that the CFPB wants to make sure, first and foremost, that consumers’ funds are safe, especially because not all prepaid accounts are structured so that they are protected by deposit insurance. The agency also wants to make sure that consumers have access to clearly written disclosures on card terms and fees before they even open a prepaid account. In the hearing, the CFPB also discussed a proposal to extend Regulation E protections to include GPR cards specifically. Furthermore, the CFPB also launched "Ask CFPB: Prepaid Cards" on its website to provide consumers with information about prepaid cards in a question-and-answer format.

Cindy MerrittBy Cynthia Merritt, assistant director of the Retail Payments Risk Forum

June 4, 2012 in consumer protection, payments, prepaid | Permalink


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September 26, 2011

I can’t use my prepaid card for that now?

The focus of the Portals and Rails blog is usually related to fraud or operational risks to the payments system. Today's blog will take a look into a different type of risk, the risk of reduced functionality for general purpose reloadable (GPR) prepaid cards. An interesting development with GPR prepaid cards has risen out of the recent Regulation II (Reg II) ruling. Considering that 1.3 billion general purpose prepaid card transactions were conducted in 2009, according to the 2010 Federal Reserve Payments Study, changes affecting GPR prepaid cards could affect many people.

Reg II, which was instituted in response to the statute commonly referred to as the Durbin Amendment, has an unintended consequence. Consumers risk losing some payment functionality with prepaid cards, including the ability to have funds auto-drafted via ACH from GPR prepaid cards. The risks of unintended consequences such as this one has not gone unnoticed by the Federal Reserve Board. In fact, during the June 29 Open Board Meeting, Governor Duke expressed her concern on this topic and would eventually like the Board to "undertake a study to quantify the overall effect of this rule on consumers."

With the Reg II interchange cap set to go into effect on October 1, many institutions are implementing new checking account fees and debit card fees that will undoubtedly make checking accounts and debit cards costlier for consumers. However, outside of eliminating or reducing rewards, institutions will offer consumers the same benefits and functionality for debit cards as they did before Reg II. It does not appear that the same can be said for the functionality and convenience of GPR prepaid cards.

To be exempt from the interchange cap, a GPR prepaid card must be the only means for a consumer to access the funds on that card or the card issuer must qualify for the small-issuer exemption (assets of less than $10 billion). If the consumer can access funds on a GPR prepaid card issued by a large issuer (assets of $10B or more) with a check, ACH, wire, or other account transfer method, then the card is viewed as a "deposit account" and therefore not exempt from the Reg II interchange cap. It was critical that the regulation include this language concerning GPR prepaid cards to prevent the widespread evasion of the interchange cap by issuers labeling traditional debit cards and their underlying deposit accounts as prepaid cards.

Conceivably, a GPR prepaid card issuer could be exempt from the Reg II interchange cap by eliminating payment functionality beyond the purchasing function of the prepaid card. Under this scenario, consumers would no longer be able to use their GPR prepaid cards to auto-draft funds via ACH from the card to pay recurring bills, such as utility bills.

According to recent comments by the CEO of Green Dot, the largest GPR prepaid card program manager, "all Green Dot managed programs, including our Walmart MoneyCard program, will be exempt from interchange restrictions under the Durbin interchange amendment and therefore, our programs will not be subject to lower interchange." A recent article in the American Banker noted that Green Dot would need to either remove features of its cards or switch bank issuers (neither of Green Dot's current issuers can qualify as small) for its cards to be exempt from the interchange cap.

Implications for GPR prepaid card users
With Green Dot cards set to be exempt from the Reg II interchange cap, many GPR prepaid card users should prepare for the loss of the direct debit functionality of their cards. And with the loss of this payment option, prepaid card users that currently use their cards' direct debit functionality to pay bills will now be more at risk of making late payments and having to pay the accompanying late fees. Furthermore, because many recurring billers, including utility companies, often charge a fee for card-based payments, GPR prepaid card users can expect to pay a service fee for paying some of these bills. To avoid these service fees for card-based payments, GPR prepaid card users may be forced to make cash payments in person, which can be both inconvenient for the consumer and costly for the biller.

A final thought
Perhaps the most surprising information from the Green Dot announcement is the fact that the WalMart Money Card will also be exempt from the interchange cap. With merchants being some of the biggest proponents of the Reg II interchange cap, it's interesting to learn that a merchant cobranded prepaid card will be stripped of a feature that provides consumers with a free, safe, and convenient way to pay bills all in the name of earning the higher interchange and presumably maintaining low costs for consumers. Given the utility of GPR prepaid cards for the un- and underbanked population, will removing electronic payment functionality from the cards further disenfranchise these consumers from banks? Or would increasing consumers' cost for the product to maintain its current functionality lead this segment away from electronic payments and back to cash?

By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

September 26, 2011 in payments, prepaid, regulators | Permalink


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Although article focuses on loss of direct ACH debit from prepaid cards, these same programs are also eliminating their web billpay offerings -- this is probably an even bigger customer impact as web billpay usage exceeds that of direct debit.

Posted by: dave fortney | October 3, 2011 at 10:25 AM

How absurd that a piece of legislation intended to curb debit interchange earnings for banks is singling out transactions that do not generate any interchange (ACH, checks).
Under-banked people encouraged by the government to receive their tax refunds into prepaid cards will be delighted to learn that they can no longer pay their bills conveniently with the money received...
There are plenty of non-evil large banks that will think twice before offering prepaid cards as an entry product, if the cards loose a large part of their usefulness.

Posted by: Patrice Peyret | September 27, 2011 at 09:02 PM

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September 19, 2011

The prepaid market: Growth and sophistication mean more risk

FinCEN has released its final rule on prepaid products, and a key feature expands the Bank Secrecy Act (BSA) compliance obligations to include providers and sellers of certain types of prepaid access devices. In March, we discussed FinCEN's proposed rule on prepaid products. The rule was drafted with the intent to address potential money laundering risks in prepaid access devices.

The final rule, released July 29, also replaces the term "stored value" with "prepaid access." The purpose of changing the nomenclature was to cast a broader net by covering not only prepaid access devices like cards, but also emerging prepaid access devices such as key fobs and mobile phones. The new definition is broad enough to cover any type of device that can serve as a portal to funds that have been paid for in advance and are retrievable and transferable.

Prepaid access devices are available in a wide variety of formats. Some types of prepaid access devices come in the typical card format, while others can exist in virtual form, such as an electronic serial number.

Growth of prepaid access
There is good reason for FinCEN's interest in prepaid products. Growth in consumer adoption and increased government activity (payout of government benefits, including unemployment and social security, among others) have accelerated the acceptance rate of prepaid products in recent years. Mercator Advisory Group predicts in its Seventh Annual Prepaid Market Forecast that the total dollars loaded onto prepaid cards may climb to $672 billion by 2013.

The Office of the Comptroller of the Currency (OCC) has also responded to the growth and sophistication of the prepaid market by releasing guidance to national banks that offer prepaid products with advanced functionality. The guidance advises national banks to develop comprehensive risk management policies and procedures to guard against potential fraud. The OCC expressed that prepaid products offering features such as international funds transfers, card-to-card transfers, and Internet transfers can potentially expose banks to a variety of risks that may not be in line with the banks' business strategies or risk appetites.

Newly regulated entities: Sellers and providers of prepaid access
Providers of prepaid access are now required to comply with the Bank Secrecy Act's regulations related to Money Services Business (MSB). Some of those requirements entail maintaining adequate anti-money laundering programs. The type of BSA program will depend on the risk appetite, size, customer base, and geography of the sellers and providers.

Under the new rule, prepaid access providers must retain transaction-specific records generated in the ordinary course of business for five years. The records collected must be easily accessible upon request from FinCEN or other law enforcement. Both providers and sellers of prepaid access are subject to Suspicious Activity Reporting (SAR) and Currency Transaction Reporting (CTR), but only providers are required to register with FinCEN once every two years.

Prepaid products exempted
For the first time, closed loop prepaid products are regulated if more than $2,000 can be loaded on the device on a given day. FinCEN acknowledged that although closed loop prepaid access is generally considered an unattractive, inefficient, and unlikely means of moving large sums of illicit money, law enforcement cautioned FinCEN that closed loop prepaid access in large dollar amounts can be vulnerable to criminal enterprises intending to launder funds. This partial exemption for closed loop prepaid access addresses law enforcement's money laundering concerns regarding a limited segment of closed loop prepaid access market, while still exempting the retail sale of closed loop prepaid of $2,000 or less.

Also regulated for the first time is low-value ($1,000 or less/day) open loop prepaid access, if it can be used internationally, transferred between or among other persons (P2P), or reloaded by a nonbank. The restrictions placed on the open loop prepaid access are based on the device's functionality and not on what it can be used to purchase.

Exempt from most of the new rule are prepaid access devices that FinCEN determined posed a decreased risk of money laundering, terrorist financing, and other criminal activities. Those devices include prepaid access to funds for payroll, government benefits, and incentives, so long as the funds cannot be used internationally, do not have P2P capabilities, and cannot be reloaded by a nonbank.

The rule's effective date is September 27, 2011. However, compliance for registration of MSBs does not take effect until January 29, 2012.

Photo of Ana Cavazos-WrightBy Ana Cavazos-Wright, senior payments risk analyst in the Retail Payments Risk Forum at the Atlanta Fed

September 19, 2011 in payments, prepaid, regulators | Permalink


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March 21, 2011

FinCEN proposed new rule addresses money-laundering risks in prepaid products

While prepaid payment products still represent a small percentage of today's electronic payments, their use is rapidly growing. According to the 2010 Federal Reserve Payments Study, the number of prepaid card transactions increased 21.5 percent each year from 2006 to 2009. Most prepaid payments are enabled by plastic cards, but today's technology can enable the same payment functionality in other form factors, including mobile phones.

As the market for these prepaid products continues to develop and grow, the Financial Crimes Enforcement Network (FinCEN) has been watchful of their potential money-laundering risk exposure and issued a proposed rule addressing various kinds of prepaid access devices. In its proposed rulemaking notice, FinCEN announced that the rule would cover not only cards but also such access devices as mobile phones, key fobs, and any other device that can serve as a portal to funds paid for in advance and allow a consumer to retrieve or transfer these funds.

Prepaid access devices and money laundering risks
Many of the same factors that make prepaid access devices attractive to consumers can make them vulnerable to criminal activity. For instance, the ease with which these devices can be obtained along with the potential for anonymity—which is the case with nonreloadable open-loop cards, for example—as well as the ease with which money can be loaded onto them can make them potential money-laundering vehicles.

To help identify potential risks related to prepaid access devices, FinCEN formed a subcommittee within their Bank Secrecy Act Advisory Group (BSAAG). The subcommittee has identified numerous risks, such as funding with cash from stolen credit cards and virtual money cards that allow individuals without a bank account to access illicit cash via ATMs globally. Some high-profile criminal activities have also surfaced, exposing some of these potential risks.

Because some products are perceived to be less likely than others to be used for money laundering, FinCEN has excluded certain prepaid access devices from its rulemaking, including payroll cards, government benefit cards, heath care access cards, closed-loop cards, and products that allow access amounts less than $1,000.

Disrupting, detecting, and deterring the illicit flow of funds
Disrupting the flow of funds can create a less-than-ideal environment for criminals attempting to conceal the sources of their illicit funds. FinCEN's proposed rule is one way to accomplish this disruption. By implementing additional systemic safeguards and filling gaps in the prepaid environment with stronger regulatory controls, the agency hopes to make it more difficult for criminals to use prepaid payments products for illicit purposes.

Ultimately, the goal of the proposed rule is to enhance the regulatory framework for prepaid access devices while finding ways to promote development and growth in the prepaid industry and discourage wrongdoers from misusing prepaid products. For now, FinCEN's final rule is pending release, but if it is adopted as proposed, it would expand Bank Secrecy Act compliance obligations to prepaid access devices beyond plastic prepaid cards to include emerging prepaid products.

Photo of Ana Cavazos-WrightBy Ana Cavazos-Wright, senior payments risk analyst in the Retail Payments Risk Forum at the Atlanta Fed

March 21, 2011 in crime, fraud, money laundering, payments risk, prepaid | Permalink


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My research suggests that these proposed rule changes will have a significant negative impact on the prepaid market and yet I am unable to find anyone in the prepaid industry that believes these proposed rules will prevent most of the crimes you identified. In particular the "high-profile criminal activity" you identified is explicitly not prevented by these proposed rules since payroll cards are excluded.

If FinCEN were to document how these proposed rules would prevent specific criminal activities, I think it is likely the prepaid industry could prove FinCEN wrong. More importantly, if FinCEN were to work directly with the industry, I am positive more effective solutions could be identified that would cause far less disruption to the prepaid market.

Preventing disruption is important because these prepaid products are the best hope for providing low cost access to financial services for the unbanked and under served. Even as the FDIC decries the lack of affordable financial services for Low & Moderate Income families, FinCEN proposes new rules that I believe will greatly increase the cost associated with delivering financial services to that same audience -- but likely with no benefit to law enforcement.

Posted by: Timothy Sloane | March 22, 2011 at 02:32 PM

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November 29, 2010

Prepaid in the mobile channel: Balancing financial inclusion and risk management

Payment services are coming to your mobile device—even though consumer adoption remains low in the United States, as are near-term prospects in light of reports about security concerns. Financial institutions, carriers, and others are experimenting with trial products and services to try to understand and respond to consumer demand for mobile services. Here in the U.S., the mobile device is emerging as an access device for legacy payment mechanisms like credit and debit cards or deposit account transfers. A viable payment mechanism for consumers to access via the mobile channel may be stored value, using the cell phone instead of a plastic card as the form factor. With the recent economic downturn, prepaid is emerging as an alternative to paper-based payments, allowing some consumers with limited access to credit to continue to participate in the electronic economy.

Some prepaid products carry potential risks because of the anonymity associated with them. The question we face is, how will we balance the potential risks of identity theft and money laundering as prepaid services shift to the mobile channel?

Recent growth in prepaid
Prepaid cards are growing in popularity, especially with the advent of reloadable, open-loop payroll cards that are branded by the major card networks and accepted at ATMs and merchants' points-of-sale. (Open-loop cards are those that consumers can redeem at different establishments. Closed-loop cards are those that the consumer can redeem at a specific establishment, which is also the issuing provider.) Since many carriers have offered prepaid airtime plans for years, the transition to a prepaid "mobile wallet" may be a seamless one. The mobile wallet is expected to operate the same way as a prepaid card, with monetary value loaded and stored on it. Because stored-value cards allow unbanked and underbanked consumers to participate in the electronic economy, their use is growing.

Open loop cards growing faster than closed loop
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Growing population of underbanked consumers
Financially mainstream consumers in the U.S. already have a multitude of safe, secure, and reliable payment choices, so they have little incentive to use their cell phones to access those payments. But a growing segment of the population is underserved by mainstream financial services. ("Underserved" individuals are those who may have a checking or savings account but rely on alternative financial services such as nonbank money orders, check-cashing services, payday loans, or pawn shops.) The increase of the underserved is in part a reflection of the weak economy, high unemployment, and reduced access to credit for many consumers. The FDIC estimates that 7.7 percent of U.S. households are unbanked and an additional 17.9 percent are underbanked.

It might be useful to compare the U.S. unbanked market to those in other countries where mobile payments and banking initiatives are in various stages of deployment.

Statistics on the unbanked populations in developed and emerging markets
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Emerging markets, such as sub-Saharan countries and India, with higher populations of consumers without access to traditional financial services are experiencing rapid adoption of mobile financial services. For example, the success of M-PESA, a mobile phone-based financial service offered by Kenya's Safaricom, has become a business model for other developing countries. In the three years since its inception, M-PESA's customer base has reached 9 million users.

Growth of M-PESA customer base
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Improving security and risk management of prepaid mobile
A number of improvements have been made in recent years in the way some prepaid cards—like payroll cards, for example—can be monitored. Open-loop cards that are branded by the major networks allow the owner to contact the issuing payment service provider if the payment card or device is lost or stolen. And many prepaid issuers will provide periodic statements detailing balances and fees. Still, concerns remain with gift cards and other closed-loop products that may not include the security features of the open-loop cards. In response to these concerns, FinCEN's proposed rulemaking should provide the industry with guidance on how to exercise oversight and control in prepaid transactions.

With respect to the mobile handset, technology is changing rapidly and the potential for improved security in the handset for authentication and identity credentialing looks promising. Given the ability for prepaid issuers to tighten the controls in card registration processes, the mobile device may be a more secure channel than today's card-based prepaid alternatives. In that case, we may see the prepaid services driving consumer confidence for more mobile-based financial services going forward.

By Cindy Merritt, assistant director of the Retail Payments Risk Forum

November 29, 2010 in identity theft, mobile payments, money laundering, prepaid | Permalink


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June 21, 2010

Will the migration to mobile payments be tempered by potential money laundering risks?

Generally, mechanisms that hold value, store it, and transfer it anonymously create a potential money laundering risk. The mobile phone in the United States today is slowly beginning to function as a conduit for payments while possibly providing users a certain degree of anonymity. Researchers predict that almost half of all mobile phone users worldwide will migrate to mobile payments by 2014.

Mobile phones serve as a means for accessing financial services, and, in some parts of the globe, mobile payments are providing access to financial services where traditional banks could not. Arguably, monitoring the movement of money via mobile transactions, particularly with a prepaid mobile, can be challenging. According to a senior trial attorney with the Department of Justice, users who provide false identification at the time of purchase or service providers who maintain poor records thwart the mechanisms that could track the origination or transfer of funds, making the mobile payments channel vulnerable to use by money launderers. In fact, the Bureau of International Narcotics and Law Enforcement Affairs of the U.S. Department of State released an article identifying the potential for mobile payments to be used as vehicles for money laundering.

But how much do we know about the money laundering risks potentially associated with mobile payments?

Emerging payments technology: Smurfing goes digital
Money laundering is generally described as having three sequential elements: placement, layering, and integration. However, not all money laundering transactions involve all three elements. Keeping up with shrewd money launderers who look for ways to exploit the payments system can be challenging. Smurfing is one basic technique of money laundering. Essentially, criminals move large sums of money by breaking the funds down into smaller amounts to avoid triggering currency reporting requirements and thereby lessen the risk of detection by authorities. Smurfing requires some ingenuity, but mostly it requires a small army of people, or smurfs, willing to go from one bank to the next to make the small, daily deposits.

In recent years, a variation of smurfing known as digital value smurfing (DVS) has emerged. DVS also involves the breakdown of large sums of money into smaller sums, but the money launderer moves the money electronically. DVS is considered the next generation of smurfing because as the shift from paper to electronic payments grows, digital smurfers can exchange cash for digital value in the form of stored value cards or possibly stored value on the mobile phone. Unlike traditional smurfing, which requires multiple smurfs to move numerous sums of money between financial institutions, a single smurf can do all the work by operating with multiple accounts, including mobile payment bank accounts, prepaid mobile phone accounts, or Internet payment accounts.

If smurfers are able to transfer stored value funds from one mobile phone to another or to other devices without using a bank for the transfer, they would bypass financial reporting requirements. They could also seriously hamper law enforcement's and the banks' monitoring and detection efforts. Could this convergence of financial services and telecommunications impede anti-money laundering efforts?

Making mobile payments more secure
Responding to the global growth in mobile payments, some vendors are providing improved security solutions for mobile money transfers, while other service providers have set limits on the number and amounts of mobile payment transactions and sources of funding and have employed comprehensive "know your customer" programs. Money laundering detection and prevention is an ongoing and difficult undertaking, one that must keep pace with advances in technology that promote fast and efficient movement of funds.

The rapid global growth of mobile payments presents ostensible opportunities for the adoption and enforcement of anti-money laundering compliance requirements in the mobile space. On May 26, 2010, a bill was introduced that would institute an identification requirement for the purchase of prepaid mobile devices, closing the anonymity gap and enhancing the monitoring and detection of potential payments activities. Examining the potential for money laundering risks in mobile payments is the best way to ensure that this new payments channel is not abused, all the while permitting its continued growth and adoption.

By Ana Cavazos-Wright, senior payments risk analyst in the Retail Payments Risk Forum at the Atlanta Fed

June 21, 2010 in mobile payments, prepaid | Permalink


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