AML CHALLENGES
established for other Money Services Business categories. The $1,000 threshold has
also been shown to yield the greatest utility
of information for law enforcement and their
financial crime investigations. Furthermore,
$1,000 appears to be a reasonable and sufficient amount to cover consumer’s needs
while also helping to maintain low product
risks.3 (Ibid)
It is important to note these limitations
cannot be applied to everyone; therefore,
some exceptions are necessary. When
dealing with government agencies or other
verifiable employers that issue direct
deposits exceeding $1,000, financial institutions will want to decide if additional parameters to suit those specific customers should
be established.
Establishing a Customer Identification
Program (CIP)
A vital step in establishing a sound and
secure prepaid card program is implementing a Customer Identification Program
(CIP) that captures the required information
and reasonably verifies the applicants, prior
to the card being issued. By gathering sufficient identification details about a customer
and implementing a rigorous system to verify
those customer details, financial institutions
can lessen the anonymity factor related
to prepaid cards. The CIP must include
obtaining the required pieces of information
such as the customer’s name, date of birth,
physical address and government-issued
identification number, while also making
sure the steps taken