Kris Andreassen concentrates her practice in financial services matters, including issues pertaining to the Bank Secrecy Act (BSA), other anti-money laundering (AML) laws and regulations, Office of Foreign Assets Control (OFAC) regulations, and state regulation of money services businesses (MSBs).  She has considerable experience in assisting financial institutions, including banks, credit unions, broker dealers and MSBs, in developing, implementing and reviewing BSA/AML and OFAC compliance programs and conducting risk assessments. She has counseled numerous banks, prepaid card program managers, processors and distributors regarding all aspects of the Financial Crimes Enforcement Network’s (FinCEN) recent prepaid access rule, for both open and closed loop prepaid products.

Kris regularly advises MSBs, including many players in the prepaid card/stored value and emerging payments space, in evaluating state money transmitter licensing requirements and exemptions, obtaining licenses and ensuring ongoing compliance with state laws.

Kris also frequently advises clients on the various state consumer protection and abandoned property laws applicable to prepaid cards and emerging payments. She also counsels clients on a number of Federal Reserve Board and Bureau of Consumer Financial Protection (CFPB) regulations, including those governing electronic fund transfers (Reg E), international remittance transfers, and interchange (Reg II).

Kris is a co-author of the Network Branded Prepaid Card Association’s bi-weekly Government Update, and a contributing editor to Paybefore Legal.  As such, she regularly monitors and reports on pending federal and state legislation and regulations in the areas of anti-money laundering, money transmitter licensing, consumer protection and abandoned property laws.

Bar and Court Admissions

District of Columbia, 2005

Maryland, 2004

Education

Duke University, J.D., cum laude, 2004

Carnegie Mellon University, B.S., with honors, Phi Beta Kappa, 2000

Publications

• "FinCEN/FDIC Assess $15 Million Civil Money Penalties Against Bank for BSA/AML Violations," Lexology.com (Nov. 30, 2012)
• "FinCEN Issues Advisory on Third Party Payment Processors; Heightened Regulatory Focus May Require Banks to Rebuild Their Systems or Exit Business Lines," Lexology.com (Nov. 29, 2012) (co-authored with John ReVeal)
• "Enforcement Actions on the Rise; What Prepaid Can Do Now," Paybefore Legal (Oct. 11, 2012)
• "CFPB Issues First Enforcement Action," Lexology.com (Oct. 4, 2012)
• "CFPB Issues Bulletin on Marketing Credit Card Add-On Products," Lexology.com (Oct. 4, 2012)
• "Federal Reserve Board Issues Final Interchange Fraud Adjustment," Lexology.com (Oct. 1, 2012)
• "CFPB Seeks Comments on Preemption of State Gift Card Escheat Laws," Bankbryancave.com (Oct. 1, 2012)
• "FinCEN Announces September 28 Customer Due Diligence Roundtable; Releases Prepared Remarks from July Hearing," Lexology.com (Sept. 20, 2012)
• "With Recent Changes Issued by the CFPB, Final Remittance Transfer Regulations to Become Effective February 7, 2013," Lexology.com (Sept. 8, 2012) (co-authored with Judith Rinearson)
• "CFPB Focusing on General Purpose Reloadable Prepaid Cards," Lexology.com (July 2, 2012) (co-authored with Linda Odom, John ReVeal and Judith Rinearson)
• "CFPB Proposes Rule to Supervise Nonbanks Posing Risks to Consumers," Lexology.com (May 30, 2012)
• "Gift Card Rule Compliance Date Fast Approaches," Lexology.com (March 27, 2012) (co-authored with Margo Strahlberg)
• "FinCEN Eyeing New Customer Due Diligence Regs, Could Have 'Profound' Impact on Prepaid," Paybefore Legal (March 2012)
• “FinCEN Seeks Comment on Potential New Customer Due Diligence and Beneficial Ownership Regulations,” Lexology.com (March 1, 2012)
• "Final CFPB Remittance Transfer Regs Broader than Proposed," Paybefore Legal (Feb. 2012)
• “FDIC Seeks Guidance on Payment Processor Relationships,” Lexology.com (Feb. 6, 2012)
• “CFPB Seeks Suggestions for Streamlining Inherited Regs,” Lexology.com (Jan. 10, 2012)
• “FinCEN Issues NPRM Requiring Cross-Border Reporting for Prepaid Cards,” PayBefore News (Oct. 2011) (co-authored with Judith Rinearson)
• "Calif. Takes on Payroll Cards--Again," Paybefore Legal (Sept. 2011)
• "Groupon/LivingSocial Litigation: Hidden Liability for Offering Deep Discounts," Paybefore Legal (May 2011) (co-authored with David Zetoony)
• "Long-running Rebate Card Class Action Against AT&T Settled," Paybefore News (April 2011)
• “Developments in the Regulation of Prepaid Payment Products Under State Money Transmitter Licensing Laws,” The Business Lawyer (Nov. 2009) (co-authored with Judith Rinearson

Professional Affiliations

• American Bar Association
• Maryland Bar Association

• Former Co-Vice Chair to the Payments Fraud Task Force for the American Bar Association’s Subcommittee on Cyberspace Law