The management and owners of iCARD Systems (iCARD) is committed to combating money laundering. iCARD employees will actively search for suspicious activity.

Designation

iCARD is an agent for the bank and is not designated as an MSB by current FINCEN rules. As an agent for the bank, all AML reporting will ultimately be filed by its issuing financial institution.

SAR Reporting

When suspicious activity is discovered, management will have ten (10) business days to conduct review. Any recommendations will then be made to iCARD's designated bank representative. Unless otherwise requested in writing, iCARD's bank, not iCARD, shall file the SAR.

All supporting evidence for the SAR will be maintained for a minimum of five (5) years, and will be securely stored.

Management will report to the owner the number of SARs filed each month, along with brief a summary as to dollar amount of the suspicious activities and why they were deemed that way.

CTR Reporting

iCARD does not engage in currency transactions. As such, iCARD does not file Currency Transaction Reports (i.e.: CTR-Form 104). In the event iCARD did engage in currency transactions CTR-Form 104 must be filed on any amount over $10,000.

Money Laundering - Defined

Money laundering can have two definitions:

1) It is the introduction of illegally obtained currency into the banking system.

2) It is using the banking system to illegally hide currency that was lawfully obtained.

It is not hard for criminals to obtain currency. However, until the currency is deposited into the banking system, their ability to utilize it is restricted. When banks knowingly accept the cash deposits of criminals, they legitimize (or launder) the proceeds. Accordingly, criminals must do business with banks.

Suspicious Activity - Defined

It is impossible for management to define all activity that would qualify as suspicious. However, the following guidelines quantify the types of suspicious activities that iCARD will monitor for.


Suspicious Activity - Corporate Prepaid Visa Card Orders

1. Non-personalized bulk card orders totaling more than $25,000 that are made to small business or companies not under contractual agreement with iCARD.
2. Bulk non-personalized cards delivered to the same address, but ordered under a different company name.
3. Bulk non-personalized cards delivered to multiple locations, but ordered by the same company.
4. Multiple bulk order requests within a month made by a company who is not under contractual agreement with iCARD.
5. Requests for cards to be delivered overseas.
6. Payments on orders over $5,000 made by credit card.
7. Bulk non-personalized card orders comprised of high-denominated cards (i.e.: >$250). Note: iCARD program limit on non-personalized cards is $750, however, as a rule iCARD does not issue cards in amounts over $500.
8. Payments made by incoming wire from an overseas bank; or payments made by check drawn on an overseas bank.
9. Orders placed by companies unwilling to provide identifiable information or who have supplied an incomplete or inaccurate profile.
10. Multiple accounts by same user.

Suspicious Activity - Consumer Prepaid Visa Card Orders

As a result of the Credit Card Act of 2009, which placed limitations on gift card fees and expirations, iCARD ceased sales of prepaid Visa cards to consumers as of January 1, 2010. Should iCARD resume sales to consumers, it will review its policies and practices for offering cards to consumers.

Enhanced Due Diligence for New Accounts

One of the best ways for iCARD to avoid being an unknowing accomplice to money launders is to properly identify new customers. In addition to collecting the following information on each account, the information is be verified by an iCARD employee through phone calls, Internet search, and third-party verification systems, such as FINEINsearch.com to verify tax ID numbers.

If a customer refuses or is unable to provide the requested information within ten (10) business days of opening his or her account, the account may be closed and their order cancelled.

Minimum Identification Requirements - Corportate Accounts

1. Name of Person Placing Orders
2. Supervisor’s Name
3. Company Name
4. Company Description
5. Web Address
6. Fed Tax ID / EIN
7. Company Address
8. Email & Telephone


Minimum Identification Requirements - Consumer Accounts

Not offered at this time.

Dollar Limits for Filing an SAR

The following guidelines will be used in determining when to file an SAR

1. Suspected insider abuse - Report any amount.

2. Suspicious transactions where the bank has identified a suspect – Report if amount equals or exceeds $5,000.

3. Suspicious transactions where the bank has not identified a suspect - Report if amount equals or exceeds $25,000

4. Known violations of the Bank Secrecy Act - Report if amount equals or exceeds $5,000.

The management will recommend filing SARs for amounts less than those specified above, if he or she has reason to believe the transaction is tied to an illegal activity.


Systems for Detecting Money Laundering

iCARD uses phone verification, Internet search and third-party systems to verify new accounts. In addition, iCARD's processor, FIS, runs OFAC checks on all card accounts.

Additionally, employees are to receive annual training on how to identify money laundering operations.


Identification of High-Risk Accounts

Certain types of business are more likely to be involved with money laundering. Accordingly, all businesses that are classified as one of the following will receive increased scrutiny from the BSA Officer.

1. Check cashing
2. Currency dealer or exchanger
3. Convenience stores that sale travelers checks and/or money orders
4. Adult establishments
5. Casinos or other gaming establishments
6. Used car or motorcycle dealers that finance their own sales
7. Used boat dealers that finance their own sales
8. Movie theaters
9. Liquor stores
10. Apartment houses
11. Hotels


Procedures for Monitoring Compliance with this Policy

A minimum of once a year, management will review the suspicious activity file. Management will ensure that all identified suspicious activity was reviewed and appropriately handled.

Management Training

Management will be allowed to attend two (2) one-day training classes per year. He or she will get to choose the training.

For additional information, please refer to fincen.gov; or contact iCARD's Chief Operating Officer, Scott Walker, 1-636-489-4698 x4002, scott.walker@icardsystems.com.