FinCEN published proposed regulations expanding anti-money laundering obligations under the Bank Secrecy Act for providers and sellers of prepaid access. The regulations are mandated by the Credit Card Accountability, Responsibility, and Disclosure Act of 2009, and are intended to fill the regulatory gap resulting from the spread of and innovation in prepaid access devices over the past 10 years, and their increased use as accepted payment methods. The regulations would apply to providers and sellers of prepaid access devices such as gift cards, mobile phones, electronic serial numbers, key fobs and other mechanisms providing a portal to funds that have been paid for in advance and are retrievable and transferable, who would have to establish AML programs and comply with CTR filing requirements. They would have to establish policies and procedures to verify the identity of customers who obtain prepaid access through a prepaid program and retain customer identifying information, including name, date of birth, address and identification number, for five years. They would also become subject to the SAR filing requirements as other types of money service businesses.