An Assesment of FinCEN’s Initiatives in the Emerging Payments Space: Virtual Currency Supervision and aCheck Back on the Prepaid Access Rule
Marilyn Barker CAMS
Sole Proprietor
The Law Office of Marilyn D Barker
Peter S. Alvarado
Senior Manager, Anti-Money Laundering Consulting
Deloitte Transactions and Business Analytics LLP
- Assessing FinCEN’s guidance on virtual currency
- Key terms; what is covered and what is not
- Impact on emerging payment systems
- Bitcoin not money transmitters
- SAR’s flagging Bitcoin
- Long-term outlook on virtual currency vs. gift cards
- How will merchants react?
- Check back on FinCEN’s prepaid access rule
- How have companies complied with the rule?
- Lessons learned
- Evaluating new and emerging guidance relating to prepaid access
- Impact of the prepaid access rule on innovative payment products and systems
- Assessing the interplay between FinCEN’s virtual currency guidance
and the prepaid access rule
- Can a virtual currency fall outside of both the FinCEN guidance on virtual currency and the prepaid access rule?