The feasibility of US government plans that would require travellers to add pre-paid card balances to declaration reports when they cross borders have been called into question.
Last October the Treasury's Financial Crimes Enforcement Network (FinCen) outlined plans to expand the scope of its cross-border reporting requirements - designed to combat money laundering and terrorist financing - to include "tangible pre-paid access devices".
However, the enforceability of such a rule, which could come into play by the end of the year, has been questioned by, among others, Cynthia Merritt, assistant director of the Retail Payments Risk Forum at the Federal Reserve Bank of Atlanta.
In a blog post, Merritt asks: "How can you tell how much money is loaded on the prepaid card to validate the declared value? In fact, how will enforcement officials even distinguish prepaid cards from credit and debit?"
According to a comment on FinCen's Notice of Proposed Rule Making (NPRM) from the Department of Homeland Security, the answer is a "handheld reader with features that will, among other things, allow law enforcement to quickly and accurately differentiate between a traveller's debit, credit, and prepaid product...in a manner which imposes minimal to no inconvenience to individuals and complies with US laws, regulations, and procedures."
In its own comment, the American Bankers Association has broadly backed the proposal as one that "satisfies the statutory mandate in a minimally intrusive way".
However, other commentators have flagged up concerns, notes Merritt. The Network Branded Prepaid Card Association, says that "a card can truthfully be reported as having just $1,000 on it; and then two hours later, the card can be loaded with funds from another location and have $15,000 on it".