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MIL Record Keeping Incude Prepaid Access Cards?

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Are gift cards (prepaid access cards) considered monetary instruments that need to be recorded on a bank's monetary instrument log? I am aware of 2011 changes related to prepaid access cards and MSBs. Has the requirement for MIL record keeping for banks been expanded to include the sale of prepaid access cards?

The easiest way to answer that question is to look at the record keeping requirement in the regulation to see if it's changed. The requirement is in 31 CFR Part 1010, section 1010.415(a), where it continues to say --

"(a) No financial institution may issue or sell a bank check or draft, cashier's check, money order or traveler's check for $3,000 or more in currency unless it maintains records of the following information, which must be obtained for each issuance or sale of one or more of these instruments to any individual purchaser which involves currency in amounts of $3,000-$10,000 inclusive:" (the information required follows).

First published on 9/3/12

First published on 09/03/2012

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