Tuesday, March 20, 2012
FinCEN said the new form is only available electronically and the legacy RMSB form can no longer be filed electronically. Therefore, in order to file electronically, MSBs located abroad but that conduct business in the United States, as well as providers of "prepaid access" (FinCEN's umbrella term for prepaid cards and other access devices underscored with pre-funded accounts), must use the new RMSB form.
FinCEN set a deadline of March 31, 2012, by which prepaid access providers must register as MSBs and be in compliance with FinCEN's AML regulations. To submit RMSB forms, businesses must register for the Bank Secrecy Act (BSA) E-Filing System.
The BSA is the federal law passed in 1970 that mandated financial institutions work with law enforcement to combat illegal money laundering activities. The BSA was recently updated with FinCEN's Prepaid Access Final Rule, which for the first time included prepaid card companies in the BSA's AML framework. FinCEN promulgated the Final Rule in reaction to the rise of prepaid cards being used as money laundering devices by terrorist groups and drug cartels. 
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