What process are you using the determine if any of yur customers are MSBS according to their prepaid access card programs? For example, do your new account people ask a series of questions to the businesses opening accounts? We are trying to beef up this part of our MSB detecting processes but are having a problem in streamlining the questions. Any help would be most appreciated.

PS: We have a number of pharmacies, conveninence stores etc. selling closed loop cards (iTunes, restaurants, etc.) We are not including these as per FINCENS rule and guidance.

Here's a sample MSB Questionnaire I found on the Internet. It may be overkill for you, but it does have some good points.

MSB Questionnaire

Thanks.

What are other banks asking for in terms of due diligence documents from prepaid card sellers? I think it would be a very remote chance of finding a customer that qualifies as a seller based on the guidelines, but if we do, I'd like to know what we should be asking for. If they act on behalf of another agent, I know we would ask for a copy of the contract. Anything else?