The Food Marketing Institute (FMI) appreciates the opportunity to respond to the Financial Crimes Enforcement Network (FinCEN) proposed rule to revise the Bank Secrecy Act (BSA) regulations applicable to Money Services Businesses (MSBs) with regard to stored value or prepaid access. FMI recognizes the national security threat posed by money laundering, terrorist financing and other illicit activities, and is committed to working with FinCEN to develop appropriate BSA oversight policies that minimize money laundering risks without unnecessarily limiting consumer access to prepaid products.
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