As required by the Credit Card Accountability Responsibility and Disclosure Act of 2009, the Financial Crimes Enforcement Network (FinCEN) has published a notice of proposed rulemaking (NPR) to amend the definition of “monetary instruments” under the Bank Secrecy Act (BSA) to include “tangible prepaid access devices.”  Previously referred to as stored value cards, certain prepaid cards, gift cards, cell phones and other instruments would be subject to international transport of currency and monetary instrument reporting (CMIR) requirements.  While the FinCEN proposal is limited to tangible devices, the NPR indicates an interest in expanding the scope of CMIR requirements to include intangible devices.

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