Presentation
Mid-Atlantic AML
Conference
___________
July 27, 2010
Green Dot Corporation
• Green Dot Corporation (GD) invented the retail
prepaid debit card product, and is the largest
company providing such products and services
through more than 40,000 stores nationwide.
• On behalf of card-issuing banks, GD provides
marketing and customer support for the sale of
prepaid debit cards.
• GD processes customer applications, collects and
verifies certain customer information and
monitors card activity on behalf of the issuer.
Green Dot Corporation
• On behalf of the card-issuing institutions, GD
markets the cards and its MoneyPak reload
products by establishing retail-selling locations.
On a daily basis, these retail sales locations
remit funds collected, via ACH, to the card-
issuing financial institution.
• Funds collected do not
belong to GD, but are
held in trust by the issuing bank for the
cardholders.
P
a
s
s
There are three ways a customer can activate a card; all use the
same verification rules.
Temporary card is activated.
Personalized Card with ATM access
arrives in the mail.
Fa
il
Generic Non-
reloadable card with
no ATM Access is
activated.
Customer can
opt for a Refund
Check in the
mail.
or
• Identity verification, including
OFAC (Experian, Lexis-Nexis)
• Internal Negative Database
•# of Cards
6
• Green Dot Instant Issue
GD AML Overview
• Collects and verifies, via Experian software,
personal information of prospective cardholders
• Activates account(s) only for an individual with a
verified SSN
• Confirms that the prospective cardholder(s)
is/are not on the OFAC/SDN list
• Monitors all transactional activity on GD
cardholders
• Files SARs and CTRS as a “money transmitter”
MSB
GD AML Overview
• Conducts annual BSA/AML training for applicable
employees
• Registered with FinCEN as an MSB “money
transmitter”
• Licensed in all States requiring GD registration
as a money transmitter
• Provides retailers selling GD cards and reload
MoneyPaks with AML educational and training
materials
Green Dot Financial Network (GDFN)
• In addition to the GD prepaid debit card program, GD operates the
GDFN, one of the largest retail-based cash acceptance networks in
the United States.
• Utilizing GDFN member bank issuers, consumers at more than
40,000 retail locations across the country can use the GD MoneyPak
to reload any prepaid card issued by a GDFN member bank.
• Currently, there are some 152 such programs (125 card-issuing and
25 non-card Bill Pay) for which GD MoneyPak can be used to load.
• Recently, Paypal was added as a partner.
• GD’s relationship to the overall transactional activities occurring
through GDFN partner’s issued cards is limited to those cash reloads
involving MoneyPak.
• GD does include AML Policy requirements in its GDFN Operating
Rules.
16
CUSTOMER EXPERIENCE
• Customer contacts Green Dot via
phone (IVR) or web
• Provides MoneyPak number & partner
account number to transfer funds
Funds verified in real-time
Good funds are guaranteed
instantly and settled next day
• Customer purchases a MoneyPak from
participating retail location
• Provides desired amount in cash to clerk
plus the service fee of $4.50-$4.95
Number on back of package is
activated at checkout (Some retailers
print it on the receipt)
Funds are available immediately
Step 1
Step 2
What Does
Provide Materials to
Retailers
Card Limitations
Initial load of
$20 - $500
10 cards
p
er SSN
Customer ID
Verification (CIP)
Paypal only
OFAC Check
Verification
Activate card(s)
No Verification
Send NPNR for value of
initial load
Track Cash
Load/Reload
Monitor Velocity of GD
Money Pak only
Dail
y
/Weekl
y
Track All Transactions
GD Money Pak only
File SARS
File as MSB
Transmitter (only for
GD Mone
y
Pak loads
)
Suspend/Terminate
Account
Green Dot Customer GDFN Customer
What Tracks
Retail Purchase of
Card - Initial Load
Activation Process
Paypal only
Reloads (Money
Pak/Swipe/Direct
Deposit)
GD Money Pak only
Total Account
Activity
Account
Suspension/Closing
Retail Sales Reload
Volume
GD MoneyPak sales
only
Green Dot Customer GDFN Customer
GD Post-Card Activation AML Controls
• Max cash load is $2,500/day; max ACH/direct
deposit loads are higher, but are subject to
spend/pull limits below
• Max spend is $2,500/day; max ATM withdrawal
is $400/day
• Based on internally-generated and adjusted as-
needed criteria, GD Compliance identifies
anomalous activity
GD Post-Card Activation AML Controls,
cont’d
• GD Compliance receives the results of
daily/weekly/monthly/quarterly electronic
queries performed on GD cardholder
transactions and household activity
• Criteria utilized include cash load velocity
(load/withdrawal); multiple cards using common
identifiers including SSN/address/telephone; and
foreign transactions
• GD Compliance receives velocity reports on retail
sales of new card and reload volume
GD Post-Card Activation AML Controls,
cont’d
• When anomalous activity is detected, account
across SSN suspended or terminated
• When appropriate, SARs/CTRs are filed by GD as
MSB-money transmitter
• Notification to card-issuing bank for its
consideration of separate SAR filing
• GD provides customer records in response to
law enforcement and 3
rd
party subpoena
requests.
GD Post-Card Activation AML Controls,
cont’d
• GD received and responded to 256 subpoenas,
and filed 1,137 SARs in 2009
• GD has testified in over 10 Federal and State
trials involving abuse of prepaid card products
Foreign Transactions
For the Third Quarter of 2009 (July – September)
• Domestic Spend by Amount: 99.842%
• Foreign Spend by Amount: 00.158%
• Domestic Spend by Transaction Count: 99.882%
• Foreign Spend by Transaction Count: 00.118%
• Domestic ATM Pull by Amount: 99.459%
• Foreign ATM pull by Amount: 00.541%
• Domestic ATM Pull by Transaction Count: 99.439%
• Domestic ATM Pull by Transaction Count: 00.561%
Questions?
Contact:
JEFF ROSS
Chief Compliance Officer
Green Dot Corporation
626-775-1713 (W)
626-298-0480 (C)
