Question:  We are instituting a gift card program.  Do we have to perform the customer identification program verification for holders of the cards?
 
Answer:  No.  Logically, the holder of the card does not have a customer relationship with the bank.  In fact, you don't even know who they are! 
 
However, be sure that you perform an appropriate risk assessment for the program.  In particular, review the Electronic Cash section of the BSA/AML Examination Manual.