With prepaid products becoming more sophisticated, federal and state regulators are asking banks that offer such products to develop comprehensive risk-management policies and procedures to guard against potential fraud and money laundering. On June 29, the Office of the Comptroller of the Currency (“OCC”) released national bank guidance on prepaid access. The bulletin provides guidance to banks to ensure they develop and implement a comprehensive risk management program that reflects the nature and complexity of prepaid access products. The OCC states its belief that the risks increase when the prepaid access program has more advanced functionality, such as international funds transfers, cardto- card funds transfers, Internet transfers, and mobile phone banking.