Netspend Distributors and Retailers

MONEY TRANSMITTER SIGNAGE AT EACH RETAIL LOCATION

Netspend has appointed you as its authorized agent to sell and reload Netspend Prepaid Cards in those jurisdictions (subject states) where Netspend is licensed as a money transmitter. As an authorized agent of Netspend in the subject states, you may be engaged in the provision of money transmission services in connection with the sale and reload of Netspend Prepaid Cards. Therefore, you are required to post such signs and/or other notifications provided by Netspend at all of your retail locations.

The signage provided to you by Netspend must be conspicuously displayed. This means a customer with 20/20 vision should be able to read it from the place where he or she would typically conduct business with you or, alternatively, on a bulletin board, in plain view, on which you post notices to the general public.

It is your responsibility to ensure that the signage is conspicuously posted in a timely manner at each of your retail locations.

To help you meet this requirement, Netspend will provide you with the signage required to be posted at the time of onboarding and periodically, as required. If you have questions or require additional signage, please contact us at partnersupport@netspend.com.

DISTRIBUTOR AML/BSA TRAINING PROGRAM

Netspend provides training to its distributors, both at the outset of a new relationship and on an ongoing basis. While Netspend continues to explore ways to more effectively train and share information, today the AML/BSA Compliance Training Program is comprised of the following components:

• Risk Management and Compliance Guidelines
• AML/BSA Distributor Training Program 
• Distributor Training Newsletter

RISK MANAGEMENT AND COMPLIANCE GUIDELINES

The following documents contain risk management and compliance guidelines (program guidelines) you are required to follow as a distributor of Netspend prepaid products. Netspend will monitor your compliance with these guidelines by making periodic visits to your stores and by monitoring transaction activity at your stores using our anti-money-laundering tools.

• Risk Management and Compliance Guidelines for Retail Distributors (examples: Convenience stores, grocery stores)
• Risk and Compliance Guidelines for Non-Retail Distributors (examples: check cashers, other alternative financial service centers, and payday lenders)

Netspend reserves the right at any time, and from time to time to request that you provide Netspend with copies of the Netspend Monthly Spoilage Log and Card Destruction Log you are required to maintain under these Guidelines. 

IN THE EVENT THAT YOU FAIL TO COMPLY WITH THESE PROGRAM GUIDELINES, NETSPEND MAY SUSPEND THE SALE AND/OR RELOAD OF NETSPEND CARD PRODUCTS AT YOUR STORES.

If you have any questions regarding these program guidelines, please contact your account manager or Netspend Partner Services at 1-866-397-5643 or partnersupport@netspend.com.

SUSPICIOUS ACTIVITY

Duty to Report Suspected Fraud – It is the responsibility of the agent, or distributor, to monitor financial transactions at their stores for any suspicious activity.

IF YOU ARE AN MSB SUBJECT TO BSA/AML REQUIREMENTS, YOU MAY BE REQUIRED TO REPORT THE SUSPICIOUS ACTIVITY AND FILE A SUSPICIOUS ACTIVITY REPORT (SAR) WITH FinCEN ON YOUR OWN BEHALF.

What YOU should do, as an agent or distributor, if the customer has demonstrated unusual or suspicious behavior:

• Write down details about the activity.
• Who was suspicious? Was it a new customer, a returning customer, etc.?
• What was unusual about the transaction or the customer’s behavior?
• How was the card purchased or load made?
• When and at what location did the purchase or load take place?
• Inform the Netspend Compliance Department about the activity.
• Complete the Unusual/Suspicious Activity Referral Form
  You can find a copy of the Unusual/Suspicious Activity Referral form here.
• If you have questions about the form, contact the Netspend Compliance Department at 1.866.914.7224(p) OR compliance@netspend.com

IMPORTANT- SUSPICIOUS ACTIVITY REPORTS (SARS) AND THEIR INFORMATION ARE CONSIDERED CONFIDENTIAL:

• DO NOT INFORM THE CUSTOMER INVOLVED IN THE TRANSACTION THAT ANY SUSPICIOUS ACTIVITY HAS BEEN OR WILL BE REPORTED. THIS INCLUDES NOTIFYING OR REPORTING OF THE UNUSUAL OR SUSPICIOUS ACTIVITY TO NETSPEND.
• THIS INFORMATION MUST REMAIN CONFIDENTIAL. DO NOT DISCLOSE WHETHER YOU FILED A SAR TO NETSPEND.