Our teller system recently added an option to include cash purchases of prepaid access cards on our Monetary Instrument Log (MIL). I am trying to determine if Prepaid Access falls under the definition of a monetary instrument?

The FFIEC BSA exam manual does not reference prepaid access in the section for "Purchase and Sale of Monetary Instruments Recordkeeping." "Prepaid Access" now has its own section but does not reference any recordkeeping requirements.

Do we need to consider prepaid access cards as a type of monetary instrument for our MIL recordkeeping?

No, no, no. You may be wise to record information on sales of prepaid access, but prepaid access is not included in the recordkeeping requirement for cash purchases of monetary instruments.

What he said.

Banks that implement record retention on their sales of prepaid access devices do so voluntarily. If your bank is considering implementing a voluntary identification and record retention structure then it should be because the cards you sell have characteristics that make them very nearly the equivalent of cash; e.g. they can be purchased in large amounts, several can be purchased on the same day, they can be purchased by non customers, 0r they can be "reloaded," etc.

Your rationale for the voluntary program is simply that you are a good citizen and do not want to be a shill for money launderers or terrorists.

The records banks keep on monetary instrument sales for cash are an anachronism; the requirements were put into place a few decades ago for a specific purpose. Today, if a bank does not sell monetary instrument sales for cash or at least does not sell monetary instruments to non customers for cash, the records have no law enforcement value whatsoever. The information on a specific check sale, which law enforcement might actually need, is readily available without centralizing them with a number of other extraneous records.

There is a far greater AML rationale for keeping records on the sale of cash equivalent prepaid access devices and your vendor is apparently willing to facilitate it. However, it's just not currently required by law or regulation.