Anti-money laundering and prepaid payment products – an update


July 12 2019

This article is Part Two of a three-part summary of the recently-published Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, 2019, released by the Department of Finance on July 10, 2019 (Finalized Regulations). The three-part series discusses prominent changes made to the Regulations and compares the changes to the Department of Finance’s initial proposed regulatory changes released on June 9, 2018 (Initial Proposal). In Part Two, we will discuss the finalized amendments relating to open-loop prepaid cards that come into force on June 1, 2021. In Part One, we considered the amendments made to the Regulations regarding virtual currency, Money Services Businesses (MSB) and foreign MSBs. In Part Three, we plan to consider other notable amendments.