Anti-Money Laundering and Terrorist Financing Prevention

It is the policy of uCharge Systems to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorists or criminal activity.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages in a stored value card program:

• Placement: Cash generated from criminal activities is loaded onto a stored value card as a monetary instrument.
• Layering: Funds are transferred or moved to other accounts or other financial institutions to further separate the money from its criminal origin.
• Integration: Funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct, but rather attempt to conceal the destination or intended use of the funds, which will later be used for criminal purposes.

uCharge has established an AML Program fulfilling the requirements of the Bank Secrecy Act and US Patriot Act in preventing the use of Stored Value Cards as vehicles for laundering money or financing terrorism. The mandate to “know your customer” and screen for individuals on the Office of Foreign Access Control (OFAC) list of individuals who should be denied access to the US financial system are a key responsibility in the programs that uCharge supports. Customer identification policies are tiered such that greater information is gathered on individuals whose financial activity with the stored value card presents a higher risk for these activities.

uCharge is committed to maintaining registration with the Financial Crimes Enforcement Network (FinCEN) as a money service business, fulfilling all requirements included in that registration.