FinCEN Releases FAQs on Pre-paid Access Rule

On November 2 2011 the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) released a set of frequently asked questions (FAQs) to assist providers and sellers of pre-paid access in understanding certain aspects of the final pre-paid access rule that FinCEN issued on July 29 2011. FinCEN makes clear that the FAQs are intended to provide interpretive guidance only, and do not supersede or replace any aspect of the pre-paid access rule. This article discusses certain aspects of the guidance that the FAQs provide with respect to the pre-paid access rule.