"Closing the loop on prepaid access: Complying with FinCEN's prepaid access rule in a digital environment" by Jonice Gray Tucker and Brendan Clegg (FinTech Law Report)
FinTech Law ReportJonice Gray Tucker, Brendan Clegg
Prepaid access vehicles have become pervasive in today’s world. Among other things, such devices provide consumers with the ability to load and store funds to be used for future purchases of products and services at various vendors, facilitating efficient and convenient cashfree, and even card-free, transactions. Over the past few years in particular, there has been tremendous growth in the number and nature of retail companies offering prepaid access devices for purchases that can be made from almost anywhere in the world, through websites and mobile phone applications. For example, today’s vacationing consumer can load funds into various applications via a phone, and then, order clothes to be delivered upon arrival, buy food en route, and purchase new music or audiobooks for the journey.