On October 17, 2011, the Financial Crimes Enforcement Network (“FinCEN”) published a proposed rule that would add “tangible prepaid access devices” to the list of monetary instruments that must be reported when they are “transported, mailed, or shipped into or out of the United States.”

Pursuant to the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”), which provides Treasury with the authority to issue regulations “implementing the Bank Secrecy Act, regarding the sale, issuance, redemption, or international transport of stored value, including stored value cards,” FinCEN has proposed a rule intended to address “money laundering and terrorist financing vulnerabilities.”