Can you tell me if we need to include gift card sales in our BSA Policy, or if we need to specify if we sell to only customers?

The product should be included in your risk assessment for that business line offering the service as it will increase the inherent and residual risk profile. It should be included whether you sell to customers or non-customers.

I agree with acquiescent. You should also include whether they are reloadable or not.

And limits on sales to one person or at one time.

Thank you all.

I suggest you call them "prepaid access devices" and address them in your BSA policy, reciting any general restrictions you impose on their sale that would make them less desirable to people involved in illegal activity.