Dear Partner,

As a follow-up to our communication in June, we have now reviewed our Know Your Customer (“KYC”) requirements and the various card transaction limits that apply to your Program.

As part of the initial stage of this review, we are changing unverified (KYC 1) Cardholder limits. Currently we permit KYC 1 Cardholders to ‘load’ their cards with up to $2,500/€2,500/£2,000 and to withdraw up to $1,000/€1,000/£800 through ATM or cash access transactions before their identity must be verified (KYC 2). After identity verification, a cardholder is permitted to use their card in accordance with the transaction limits set out in the WaveCrest Agreement (“Agreement”) or as communicated by us from time to time. Following the completion of the initial stage of our review, we are making the following changes to transaction limits for unverified cardholders:

1. The maximum cumulative load limit for unverified cardholders (KYC 1) will be reduced from $2,500/€2,500/£2,000 to $250/€250/£200 (or equivalent). This limit is the combined limit for all plastic and virtual cards issued to the cardholder.

2. Unverified cardholders (KYC 1) will only be able to withdraw up to a maximum cumulative limit of $100/€100/£80 through ATM withdrawal transactions. This limit is the combined limit for all plastic cards issued to the cardholder. Purchases will be allowed up to $250/€250/£200 (or equivalent) or the balance available on the card.

The above changes will go into effect on 10th December 2017 at 23:59 GMT. Unverified cardholders (KYC 1) can continue to load and use their cards within the current limits until that date.

After 10th December 2017, 23:59 GMT, any cardholders with prior loads exceeding $250/€250/£200 will not be able to load additional funds to their card. In addition, their ability to withdraw funds through ATM transactions will be limited to $100/€100/£80, including transactions prior to the 10th December 2017, 23:59 GMT.

Although load and cash access will be subject to the new limits, cardholders will be able to spend their total available balance for purchases online or at retail point of sale.

How does this affect your Program?

In order to minimize any disruption to your Program we have taken the decision that the changes above will not take effect until the 10th December 2017, 23:59 GMT.

We intend to inform all unverified cardholders of the KYC 1 limit changes through a general WaveCrest cardholder notification to be sent on 25th October 2017.

If you manage cardholder communications directly, you must notify your unverified cardholders by 20th October 2017 and provide us an evidence of your cardholder communication by 20th October 2017.

If we do not receive any evidence from you by 20th October, 2017, we will directly send a WaveCrest notification to your unverified cardholders.

The evidence required is a list with all notified cardholders, their email addresses and a copy of the template (or actual) email that was sent to the cardholders. Please send the evidence to [email protected]

The required wording for communication of these changes to cardholders is attached. You will note from this communication that cardholders are to be encouraged to either

  1. submit their identity verification documents as a matter of urgency (if applicable); or
  2. wind down the balance held on their card if they do not wish to have their identity verified.

For the avoidance of doubt, whilst these cardholders will not be able to load further funds to their cards (if they have already exceeded the $250/€250/£200 load limit), they will still be able to spend their available balance, subject to the new cumulative limits on ATM withdrawals.

Further review of the “Know Your Customer” requirements is on course to be completed by no later than the 30th November 2017 and we confirm that we will keep you fully updated as to any developments. Please be aware that it is likely that there will be an overall reduction in the maximum transaction limits that apply to our verified cards and that such reductions will be linked to the characteristics of each Program.

We thank you for your continued cooperation in providing a safe and secure payment solution to all of our cardholders.

Yours faithfully,
WaveCrest Team

NOTES:
Corporate Payout Agreement: 3.1.9 allows us to direct change in accordance with our compliance policies linking to AML.
Cardholder Agreement: 11.1 permits limits to be changed from time to time.
WaveCrest Holdings Limited is an electronic money institution licensed by the Financial Services Commission, Gibraltar.