AML CHALLENGES
issuer to maintain separate areas or departments, one to develop and train on the AML
requirements and one to perform independent testing for compliance.
also include assessment of the risks associated with offering the products through third
parties. The April 2010 FFIEC BSA/AML
Examination Manual provides a good outline
of the risk mitigation factors to consider.
Each program
manager should
have a designated
AML officer
AML policy
In addition to ensuring that its enterprisewide AML Program covers issuance of
prepaid, the issuer should also have documented AML requirements to which its
program managers are contractually required
to comply. These requirements should
include the issuer’s expectations for the
program manager’s AML policy, four pillars
and specific requirements for CIP, transaction monitoring, reporting, and OFAC.
Depending on the program manager’s other
business lines, program manager’s may or
may not be required to have their own AML
policy to address applicable AML regulations.
In those cases, the sale of prepaid cards and
the issuer’s requirements should be added to
program manager’s existing AML policy.
AML officer
Each program manager should have a designated AML officer. Depending on the size of
the company, the officer may hold multiple
positions, including but not limited to legal,
fraud, risk, finance or operations. In all
cases, the program manager’s AML officer
should have the resources needed to fulfill
their responsibilities; however, the AML
officer may have limited AML experience
depending on the program manager’s other
business lines. In those cases, it is beneficial
if the issuer can provide additional training.
Offering the program manager industry
training solutions, such as those provided by
the Network Branded Prepaid Card Association (NBPCA)2 or ACAMS, can be beneficial
for everyone.
AML training and retail agents
Program managers should be required to
attend initial and annual training on the
issuer’s AML requirements. The program
manager should also be required to provide
AML training to their applicable staff and
any retail agents. If the program manager
is using retail agents to sell ܈