Prepaid Card AML Risk
Certivus AML team8 minUpdated 2026-06-27
In brief: Prepaid cards can create AML risk where funding source, card ownership, transaction purpose, or user identity is unclear.
Key points
- Prepaid cards are not automatically suspicious.
- Risk rises where funding, ownership, or transaction purpose cannot be explained.
- Ask for evidence that links the card activity to the client and matter.
Why prepaid cards can matter in AML files
Prepaid cards can be legitimate tools for spending control and travel, but they can also make funds harder to trace where card ownership, loading source, or transaction purpose is unclear.
When to look closer
| Situation | AML question |
|---|---|
| Client uses prepaid cards for business spending | Does the spending fit the business model? |
| Card loading source is unclear | Where did the funds originate? |
| Multiple cards or users | Who controls the value? |
| Cross-border use | Does geography change the risk profile? |
| Poor records | Can the firm evidence the explanation? |
Practical response
Do not assume risk from the payment method alone. Ask proportionate questions, keep transaction evidence, and update the client risk assessment where the explanation is weak.
This guide is general information for AML risk assessment, not legal advice or fraud-investigation guidance. Use it alongside the firm's AML procedures, Action Fraud, the Fraud Act 2006, and supervisor guidance.