On September 9th, the Financial Crimes Enforcement Network ("FinCEN") issued a Notice providing administrative relief to sellers and providers of prepaid access that would otherwise be subject to certain Bank Secrecy Act ("BSA") requirements imposed by a final rule published on July 29, 2011. As a result of this administrative relief, sellers of prepaid access will have until March 31, 2012 to comply with those requirements that are scheduled to go into effect beginning September 27, 2011. Providers of prepaid access will be required to comply with some, but not all, aspects of the Final Rule by September 27, 2011; for the remaining requirements, compliance is extended until March 31, 2012.