We have a business who wants to offer their employees payroll throught prepaid access cards. My FI is considering offering them a product to accomplish this. What are the BSA issues with this product? Do I need to run CIP and OFAC on all of the employees prior to them receiving these cards as most of them will not be current customers of the bank and what monitoring, if any, is required? Any help will be greatly appreciated as this is new territory for me.