U.S. money transmitters and providers and sellers of prepaid access, among other money service businesses (MSBs), have been known to have been misused for money laundering and terrorist financing purposes. 

According to the U.S. Department of the Treasury’s National Money Laundering Risk Assessment 2015, vulnerabilities of money transmitters include the structuring of transactions below the $3,000 reporting threshold to carry out illicit payments, compliance deficiencies, provision of services through unregistered or unlicensed businesses, and the anonymous exchange of virtual currencies. The Treasury Department also highlights that although prepaid access has been made less desirable to perpetrate illicit behavior, “concerns remain with respect to the ease of transfer and transport of foreign-issued prepaid access products, given the lack of similar regulatory and industry controls outside of the United States.”

Generally, third-party payment processors (TPPPs) provide an intermediary service between merchants and banks. Since 2008, the Financial Crimes Enforcement Network (FinCEN) has issued specific guidance to address the risks of money laundering and terrorism financing posed