I did a search and couldn't locate much on this. Did you include your gift cards or travel cards as covered accounts in your ID Theft Prevention program? Why or why not? If you did, how did you include them? For example, if you incorporate CIP into your ID Theft Prevention Program, then on these kinds of cards, do you perform all of your normal CIP if a noncustomer is purchasing a gift card?

I can see an argument either way, but it seems it mostly depends on whether or not your cards are reloadable.

We treat personalized, reloadable cards as "customer accounts" subject to CIP. Vendor can provide CIP verification prior to mailing card. We do not require CIP on over-the-counter, non-reloadable cards.