I am 'assuming' that the sale of gift cards would fall on BSA and MIL reporting - has anyone already researched that liklihood?

Re-posting - any comments - guru's - anyone? Surely there's another bank out there selling gift cards - yes/no?

They are not specifically addressed, but I personally feel that is because the law(s) predate the advent of gift cards. There is no requirement to gather data as a monetary instrument. However, they certainly are "negotiable". I think (and we are trying to figure out a way to do this) that at a minimum they should be watched for suspicious activity. This would of course be a "risk based" decision at each bank.