Compliance
Waricel is committed to maintaining a strong culture of regulatory compliance. We maintain risk-based policies, procedures, and transaction controls designed to prevent fraud, money laundering, and other misuse of our services and to comply with applicable laws and regulations.
FinCEN Prepaid Access Compliance
Waricel provides a service for reloading international prepaid mobile phones. Under FinCEN regulations, an arrangement providing closed-loop prepaid access is excluded from the definition of a “prepaid program” when no more than $2,000 can be associated with a prepaid access device or vehicle on any day.
Waricel maintains substantially lower transaction limits. Individual mobile top-up transactions are limited to a maximum of $300, and each customer is limited to an aggregate maximum of $1000 per day. The value purchased through Waricel can be used only for telecommunications services associated with the designated mobile account.
In addition, FinCEN's definition of a “seller of prepaid access” includes, among other circumstances, a person that sells more than $10,000 in prepaid access to a single person during one day without policies and procedures reasonably designed to prevent such sales. Waricel's $1000 daily customer limit prevents transactions approaching this threshold.
Based on the structure and transaction limits of its services, Waricel does not operate a “prepaid program” and does not meet FinCEN's definition of a “provider of prepaid access” or “seller of prepaid access.” Accordingly, Waricel is not required to register with FinCEN as a Money Services Business on the basis of its prepaid mobile top-up activities under the Prepaid Access Rule.
Waricel nevertheless maintains risk-based compliance, transaction-monitoring, customer-verification, and fraud-prevention controls appropriate to its business and periodically reviews its regulatory obligations as its services and applicable regulations evolve.
Anti-Money Laundering and Fraud Prevention
Waricel maintains a risk-based compliance program designed to reduce the risk that its services may be used for money laundering, fraud, or other unlawful activity. The program includes appropriate policies and procedures, transaction monitoring, internal controls, customer verification measures, employee training, and escalation procedures.
Waricel reviews unusual activity and may decline, restrict, or suspend transactions or customer accounts when activity presents an unacceptable compliance or fraud risk. Waricel also cooperates with financial institutions, payment providers, regulators, and law-enforcement authorities when required or appropriate..
Customer Identification and Verification
Waricel collects customer information appropriate to the nature and risk of the transaction and may require additional identity verification when warranted. Verification may be triggered by transaction patterns, transaction amounts, account activity, payment risk indicators, or other factors identified through Waricel's compliance and fraud-prevention controls.
Customer information is handled and retained in accordance with applicable legal requirements and Waricel's Privacy Policy.
Transactional Records
Waricel collects and retains customer and transaction information for a minimum of five years. Records include transaction amounts, dates and times, destination mobile numbers, transaction identifiers, and relevant customer information. Records are maintained securely in accordance with Waricel’s Privacy Policy.
Regulatory Compliance Contact
Questions regarding Waricel's regulatory compliance program may be directed to: compliance@waricel.com