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#1329999 - 01/25/10 04:30 PM Gift Cards - ughhh - Marketing
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
Question - our marking group changed our GiftCard vendor - now, when we make a sale of an open end gift card we are unable to do any monitoring because the system does not record the name, address or other pertinant information - only the card number and amount - our former system retained all this information for us.

Do other banks sell open end gift cards - if so, how do you handle OFAC and 314a - these two issues keep popping up as a problem.

HOwever, our marketing director - thinks they know it all - and says WalMart, WalGreens, and others don't record informtion - so why do we have to. geez....

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BSA/AML/CIP/OFAC Forum
#1330541 - 01/25/10 10:49 PM Re: Gift Cards - ughhh - Marketing Tryin-2-Comply
WonderWoman Offline
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gone fishin'
I just read somewhere that the CARD Act of 2009 is putting requirements on FinCEN to implement CIP requirements with Store Value Cards.

Anyone heard of this?

I've heard we will be required to document ID, run OFAC, 314(a), etc ...

My bank is looking into Payroll cards - I could use all the help I can get.
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#1330762 - 01/26/10 02:48 PM Re: Gift Cards - ughhh - Marketing WonderWoman
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Here is a good source of information on prepaid cards.

http://www.nbpca.com/

Be sure to check out

http://www.nbpca.com/docs/NBPCA-AML-Recommended-Practices-080220.pdf
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#1331129 - 01/26/10 07:05 PM Re: Gift Cards - ughhh - Marketing WonderWoman
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Originally Posted By: (not as) newbsa
I just read somewhere that the CARD Act of 2009 is putting requirements on FinCEN to implement CIP requirements with Store Value Cards.

Anyone heard of this?

I've heard we will be required to document ID, run OFAC, 314(a), etc ...

My bank is looking into Payroll cards - I could use all the help I can get.


I have heard the same thing.

Luckily for us the 3rd party vendor we use does all of that once its entered into the system. We only sell gift and travel cards to customers.
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#1331154 - 01/26/10 07:24 PM Re: Gift Cards - ughhh - Marketing J2C
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Maybe this will help explain the Card Act of 2009 in relation to prepaid cards.

http://www.philadelphiafed.org/payment-c...rd-act-2009.pdf
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Politicians are like diapers. They need to be changed often and for the same reason.

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#1331168 - 01/26/10 07:30 PM Re: Gift Cards - ughhh - Marketing WonderWoman
Ted Dreyer Offline
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Joined: Apr 2001
Posts: 2,245
Section 503 of the CARD Act says that by February 22, 2010 Treasury is required to issue "regulations in final form implementing the Bank Secrecy Act, regarding the sale, issuance, redemption, or international transport of stored value, including stored value cards".

That's not very detailed, but if they meet the time deadline, we'll know the details in less than a month.

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#1331337 - 01/26/10 09:02 PM Re: Gift Cards - ughhh - Marketing Ted Dreyer
Tryin-2-Comply Offline
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Joined: Apr 2003
Posts: 202
Hills of TN
Thanks to all who added info.....

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#1331485 - 01/26/10 10:28 PM Re: Gift Cards - ughhh - Marketing Ted Dreyer
AnnRoy Offline
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Joined: Jun 2002
Posts: 771
South
Well I'm sure that will just further delay the updating of the BSA/AML Exam Manual, huh???? So much for annual updates to the exam since its been 2007 since the last update!!!
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#1331523 - 01/26/10 11:01 PM Re: Gift Cards - ughhh - Marketing AnnRoy
BrendaC Offline
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Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I heard that it is due out in March, but who knows. I wouldn't place bets on anything these days!
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#1331624 - 01/27/10 01:34 PM Re: Gift Cards - ughhh - Marketing BrendaC
J2C Offline
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Posts: 1,475
Big Brother knows and that's a...
Originally Posted By: BrendaC
I heard that it is due out in March, but who knows. I wouldn't place bets on anything these days!


I was on a call last week with ABA and they said they believe that it should be out by the end of this month. The speaker also said that he would not be surprised if it didn't though.

By the time they get this one out, it will be time for the next one!
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My opinion is mine only- not my employer's!


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