Critical Regulatory Challenges that Come with InternationalExpansion: Proposed Changes to Remittance Transfer Rules,Cash Disbursement Nuances, Travel Abroad Issues IncludingCross-Border Declaration Obligations and Loss/Theft of Card,and Beyond

October 6, 2014 4:40pm


David Wilford
General Counsel and Chief Compliance Officer
Wave Crest Group Limited

Barrie VanBrackle
Orrick, Herrington & Sutcliffe LLP

  • International payments moving onto cards and payments coming from abroad
  • Federal Remittance Transfer: what now triggers it?
  • Proposed changes to the remittance transfer rules: Depository institutions using estimations for exchange rates
  • Is cash disbursement subject to the rule?
  • FinCEN plan to make travelers declare prepaid cards: Currency declaration obligation; Extent to which value underlying prepaid cards must be declared at the border; Anticipating fi nal rule from FinCEN; Declaring certain amount across the border; Is carrying a prepaid card subject to declaration?
  • New issues with prepaid cards issued domestically, but cardholder suffers a loss or theft of the card while traveling in a foreign country
  • Issues with international reloading
  • International synergies or lack thereof- what can we learn from the international community?
  • E-money Directives in Europe: Practicality of adopting an e-money regime in the US to address a large segment of the market that traditional banks don’t