An Assesment of FinCEN’s Initiatives in the Emerging Payments Space: Virtual Currency Supervision and aCheck Back on the Prepaid Access Rule

March 26, 2015 4:05pm

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?