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Federal Communications Commission
Washington, D.C. 20554
)
) File No.: EB-12-IH-0076
In the Matter of
) NAL/Acct. No.: 201332080008
StanaCard, LLC
) FRN: 0018463380
)
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: January 24, 2013 Released: January 24, 2013
By the Chief, Investigations and Hearings Division, Enforcement Bureau:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (NAL), we find
that StanaCard, LLC (StanaCard) apparently violated Section 214 of the
Communications Act of 1934, as amended and Sections 63.03, 63.04,
63.18, and 63.24 of the Commission's rules (Rules) in connection with
StanaCard's unauthorized transfer of control of its domestic and
international Section 214 authority. Based on our review of the facts
and circumstances surrounding these matters, and for the reasons
discussed below, we find that StanaCard is apparently liable for
forfeiture penalties totaling twenty-one thousand dollars ($21,000).
II. BACKGROUND
2. Section 214 of the Act requires telecommunications carriers to obtain
a certificate of public convenience and necessity from the Commission
before constructing, acquiring, operating, or engaging in the
transmission of common carrier communications services over
communications lines, and before discontinuing, reducing, or impairing
service to a community. In accordance with Sections 63.03 and 63.24 of
the Rules, any "substantial" transfer of control of a carrier's lines
or of Section 214 authority requires application to and prior approval
from the Commission. Sections 63.04 and 63.18 of the Rules set forth
the information that must be included in the domestic and
international transfer of control applications.
3. "Non-substantial" (or "pro forma") transfers of a carrier's lines or
of Section 214 authority do not require Commission approval prior to
consummation. A carrier that consummates a pro forma international
Section 214 transaction, however, must provide notice of that
transaction to the Commission no later than 30 days after
consummation. This notification requirement generally does not extend
to pro forma domestic Section 214 transactions.
4. StanaCard, a Delaware limited liability company, is a resale provider
primarily of prepaid international telecommunications services. On
February 1, 2010, the Commission's International Bureau (IB) granted
international Section 214 authority to StanaCard. At that time, the
Company also obtained blanket domestic Section 214 authority by
operation of the Rules.
5. On January 27, 2012, StanaCard self-disclosed to the Enforcement
Bureau (Bureau) that it apparently had: (a) failed to timely notify
the Commission of a pro forma transfer of control of international
Section 214 authority during 2010 and (b) had not obtained Commission
approval before consummating a substantial transfer of control of
domestic and international Section 214 authority during 2010. In
response, the Bureau launched an investigation.
6. Prior to October 23, 2010, Michael Choupak held an 88.88 percent
membership interest (8000 out of a total of 9000 Class A Units) in
StanaCard and was its managing member. On October 23, 2010, Mr.
Choupak transferred half of that membership interest (44.44 percent or
4000 Class A Units) to Anastasia Koroleva. Mr. Choupak retained a
44.44 percent membership interest in StanaCard and remained its
managing member. StanaCard did not notify the Commission of this
transaction until February 15, 2012. On February 16, 2012, IB granted
StanaCard's application for approval of this transaction.
7. In a separate transaction, on June 21, 2011 Mr. Choupak transferred
his remaining 44.44 percent membership interest in StanaCard to Ms.
Koroleva, who then held an 88.88 percent membership interest (8000
Class A Units) in StanaCard. On the same day, Mr. Choupak resigned
his role as managing member and Ms. Koroleva was elected as his
replacement, putting her in control of the Company. On January 17,
2012, StanaCard filed an application for a substantial transfer of
control of StanaCard's domestic and international Section 214
authority from Mr. Choupak to Ms. Koroleva as well as requests for
Special Temporary Authority (STA) to continue providing domestic and
international service while its transfer of control application was
pending. On January 26, 2012, IB and the Commission's Wireline
Competition Bureau (WCB) granted StanaCard's STA requests. On March 2,
2012 and March 9, 2012, IB and WCB respectively approved the transfer
of control of StanaCard's international and domestic Section 214
authority from Mr. Choupak to Ms. Koroleva.
III. DISCUSSION
8. Under Section 503(b)(1) of the Act, any person who is determined by
the Commission to have willfully or repeatedly failed to comply with
any provision of the Act or any rule, regulation, or order issued by
the Commission shall be liable to the United States for a forfeiture
penalty. Section 312(f)(1) of the Act defines willful as "the
conscious and deliberate commission or omission of [any] act,
irrespective of any intent to violate" the law. The legislative
history to Section 312(f)(1) of the Act clarifies that this definition
of willful applies to both Sections 312 and 503(b) of the Act, and the
Commission has so interpreted the term in the Section 503(b) context.
The Commission may also assess a forfeiture for violations that are
merely repeated, and not willful. "Repeated" means that the act was
committed or omitted more than once, or lasts more than one day. To
impose such a forfeiture penalty, the Commission must issue a notice
of apparent liability, and the person against whom the notice has been
issued must have an opportunity to show, in writing, why no such
forfeiture penalty should be imposed. The Commission will then issue a
forfeiture if it finds, based on the evidence, that the person has
violated the Act or a Rule.
9. The issues in this case are whether StanaCard apparently violated
Section 214 of the Act and Sections 63.03, 63.04, 63.18, and 63.24 of
the Rules by willfully or repeatedly failing to provide timely notice
of a pro forma transfer of control of international Section 214
authority and by willfully or repeatedly engaging in unauthorized
transfers of control of its domestic and international Section 214
authority. We answer these questions in the affirmative. StanaCard
apparently failed to give timely notice of a pro forma transfer of
control of international Section 214 authority and apparently
neglected to obtain prior authority for the substantial transfers of
control of domestic and international Section 214 authority. Based on
the facts and circumstances before us, we conclude that StanaCard is
apparently liable for forfeiture penalties totaling twenty-one
thousand dollars ($21,000).
10. Section 63.24(f) of the Rules requires that a carrier provide notice
to the Commission that it has consummated a pro forma international
Section 214 transaction no later than 30 days after such consummation.
We conclude that StanaCard apparently willfully or repeatedly violated
this Rule in connection with Mr. Choupak's October 23, 2010 assignment
of half of his 88.88 percent membership interest in StanaCard to Ms.
Koroleva, giving her a 44.44 percent membership interest in the
Company. As a result of this transaction, Mr. Choupak and Ms. Koroleva
held equal membership interests in StanaCard, but Mr. Choupak retained
his position as the managing member, which kept him in de facto
control of the Company. StanaCard apparently failed to provide notice
to the Commission of this pro forma transfer of control of an
international Section 214 authorization within 30 days after the
October 23, 2010 transaction. StanaCard did not notify the Commission
of this pro forma international Section 214 transaction until nearly
15 months after the date the transaction notification was due. Based
on a preponderance of the evidence, we find that StanaCard apparently
willfully or repeatedly violated Section 214 of the Act and Section
63.24(f) of the Rules.
11. We also conclude that StanaCard apparently violated Section 214 and
related Rules by consummating substantial transfers of control of a
domestic Section 214 authority and an international Section 214
authority without prior Commission approval. These two apparent
violations arose from the June 21, 2011 transfer by Mr. Choupak of all
of his membership interest in StanaCard to Ms. Koroleva, his
resignation as manager of the Company, and the election of Ms.
Koroleva as StanaCard's managing member. These transactions
transferred ultimate control of domestic and international Section 214
authority from Mr. Choupak to Ms. Koroleva. These apparent violations
persisted for over six months before StanaCard filed corrective
applications. Based on a preponderance of the evidence, we therefore
find that in two instances StanaCard apparently willfully or
repeatedly violated Section 214 of the Act and Sections 63.03, 63.04,
63.18, and 63.24 of the Rules.
12. Section 503(b)(1) of the Act provides that any person who willfully or
repeatedly fails to comply with any provision of the Act or any rule,
regulation, or order issued by the Commission shall be liable to the
United States for a forfeiture penalty. Section 503(b)(2)(B) of the
Act authorizes the Commission to assess a forfeiture of up to $150,000
for each violation or each day of a continuing violation by a common
carrier, up to a statutory maximum of $1,500,000 for a single act or
failure to act. In determining the appropriate forfeiture amount, we
consider the factors enumerated in Section 503(b)(2)(E) of the Act,
including "the nature, circumstances, extent, and gravity of the
violation and, with respect to the violator, the degree of
culpability, any history of prior offenses, ability to pay, and such
other matters as justice may require," as well as our forfeiture
guidelines.
13. Section 1.80 of the Rules establishes a base forfeiture amount of
$1,000 for an "unauthorized pro forma transfer of control." We find
that StanaCard apparently engaged in one unauthorized pro forma
international Section 214 transfer of control. Accordingly, we find
that StanaCard is apparently liable for a forfeiture of one thousand
dollars ($1,000) for its willful or repeated failure to timely notify
the Commission of one pro forma international Section 214 transfers of
control.
14. Section 1.80 of the Rules establishes a base forfeiture amount of
$8,000 for an "unauthorized substantial transfer of control." The
Commission has applied that same forfeiture amount to substantial
transfers of international Section 214 authority. StanaCard engaged in
two unauthorized substantial transfers of control. These two
unauthorized Section 214 transactions persisted for more than six
months before StanaCard filed corrective STA requests, which were
granted. Taking the duration of these delays into account and applying
the factors set forth in Section 503(b)(2)(E) of the Act as well as
Commission precedent, we find that the appropriate forfeiture amount
for the two unauthorized substantial transfers of control is twenty
thousand dollars ($20,000).
IV. CONCLUSION
15. In light of the seriousness, duration, and scope of the apparent
violations, we propose forfeitures totaling twenty-one thousand
dollars ($21,000) against StanaCard, consisting of one thousand
dollars ($1,000) for failure to timely notify the Commission of one
pro forma transfer of control of international Section 214 authority
and twenty thousand dollars ($20,000) for two unauthorized substantial
transfers of control of domestic and international Section 214
authority.
V. ORDERING CLAUSES
16. ACCORDINGLY, IT IS ORDERED that, pursuant to Section 503(b) of the
Act, and Section 1.80 of the Rules, StanaCard, LLC is hereby NOTIFIED
OF ITS APPARENT LIABILITY FOR A FORFEITURE in the amount of twenty-one
thousand dollars ($21,000) for willfully or repeatedly violating
Section 214(a) of the Communications Act of 1934, as amended, 47
U.S.C. S: 214(a), and Sections 63.03, 63.04, 63.18, and 63.24 of the
Rules, 47 C.F.R. S:S: 63.03, 63.04, 63.18, and 63.24.
17. IT IS FURTHER ORDERED that, pursuant to Section 1.80 of the Rules,
within thirty (30) calendar days of the release date of this Notice of
Apparent Liability for Forfeiture, StanaCard SHALL PAY the full amount
of the proposed forfeitures or SHALL FILE a written statement seeking
reduction or cancellation of the proposed forfeitures.
18. Payment of the forfeiture must be made by check or similar instrument,
wire transfer, or credit card, and must include the NAL/Account number
and FRN referenced above. StanaCard shall also send electronic
notification within forty-eight (48) hours of the date said payment is
made to Terry.Cavanaugh@fcc.gov, Pamela.Kane@fcc.gov,
William.Kehoe@fcc.gov, and Robert.Krinsky@fcc.gov. Regardless of the
form of payment, a completed FCC Form 159 (Remittance Advice) must be
submitted. When completing the FCC Form 159, enter the Account Number
in block number 23A (call sign/other ID) and enter the letters "FORF"
in block number 24A (payment type code). Below are additional
instructions regarding the form of payment:
* Payment by check or money order must be made payable to the order of
the Federal Communications Commission. Such payments (along with the
completed Form 159) must be mailed to Federal Communications
Commission, P.O. Box 979088, St. Louis, MO 63197-9000, or sent
via overnight mail to U.S. Bank - Government Lockbox #979088,
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101.
* Payment by wire transfer must be made to ABA Number 021030004,
receiving bank TREAS/NYC, and Account Number 27000001. To complete
the wire transfer and ensure appropriate crediting of the wired funds,
a completed Form 159 must be faxed to U.S. Bank at (314) 418-4232 on
the same business day the wire transfer is initiated.
* Payment by credit card must be made by providing the required credit
card information on FCC Form 159 and signing and dating the Form 159
to authorize the credit card payment. The completed Form 159 must then
be mailed to Federal Communications Commission, P.O. Box 979088, St.
Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank -
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St.
Louis, MO 63101.
19. Any request for full payment under an installment plan should be sent
to: Chief Financial Officer - Financial Operations, Federal
Communications Commission, 445 12th Street, SW, Room 1-A625,
Washington, DC 20554. Questions regarding payment procedures should be
addressed to the Financial Operations Group Help Desk by phone,
1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.
20. The written statement seeking reduction or cancellation of the
proposed forfeitures, if any, must include a detailed factual
statement supported by appropriate documentation and affidavits
pursuant to Sections 1.80(f)(3) and 1.16 of the Rules. The written
statement must be mailed to Theresa Z. Cavanaugh, Chief,
Investigations and Hearings Division, Enforcement Bureau, Federal
Communications Commission, 445 12th Street, SW, Room 4-C330,
Washington, DC 20554 and must include the NAL/Account number
referenced above. The written statement shall also be e-mailed to
Theresa Z. Cavanaugh at Terry.Cavanaugh@fcc.gov and to Robert B.
Krinsky at Robert.Krinsky@fcc.gov.
21. The Commission will not consider reducing or canceling a forfeiture in
response to a claim of inability to pay unless the petitioner submits:
(1) federal tax returns for the most recent three-year period; (2)
financial statements prepared according to generally accepted
accounting practices (GAAP); or (3) some other reliable and objective
documentation that accurately reflects the petitioner's current
financial status. Any claim of inability to pay must specifically
identify the basis for the claim by reference to the financial
documentation submitted.
22. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
for Forfeiture shall be sent by first class mail and certified mail,
return receipt requested, to: Manlio Carrelli, Chief Executive
Officer, StanaCard, LLC, 424 West 33rd Street, Suite 410, New York, NY
10001; Michael Choupak, StanaCard, LLC, 424 West 33rd Street, Suite
410, New York, NY 10001; Anastasia Koroleva, StanaCard, LLC, 424 West
33rd Street, Suite 410, New York, NY 10001; and David E. Bronston,
Esq., Phillips Lytle LLP, 437 Madison Avenue, 34th Floor, New York, NY
10022-7021.
FEDERAL COMMUNICATIONS COMMISSION
Theresa Z. Cavanaugh
Chief, Investigations and Hearings Division
Enforcement Bureau
47 U.S.C. S: 214.
47 C.F.R. S:S: 63.03, 63.04, 63.18, 63.24.
See 47 U.S.C. S: 214(a). In 1999, the Commission granted all
telecommunications carriers blanket authority under Section 214 to provide
domestic interstate services and to construct or operate any domestic
transmission line. Implementation of Section 402(b)(2)(A) of the Telecomm.
Act of 1996, Report and Order in CC Docket No. 97-11, Second Memorandum
Opinion and Order in AAD File No. 98-43, 14 FCC Rcd 11364, 11365-66, para.
2 (1999) (Section 402 Implementation Order); 47 C.F.R. S: 63.01. This
authority does not extend to the provision of international services. See
Section 402 Implementation Order, 14 FCC Rcd at 11365-66, para. 2.
47 C.F.R. S:S: 63.03; 63.24. A transfer of control of domestic lines or of
a domestic Section 214 authority is considered "substantial" if it results
in a change in ultimate ownership or control of those lines or that
authority. See 47 C.F.R. S: 63.03(d). A transfer of control of
international lines or of an international Section 214 authority is
considered "substantial" if it results in a change in the actual
controlling party of those lines or that authority. 47 C.F.R. S: 63.24(a).
See 47 C.F.R. S:S: 63.04, 63.18.
See 47 C.F.R. S:S: 63.03(d); 63.24(f).
47 C.F.R. S: 63.24(f).
47 C.F.R. S: 63.03(d)(1). Notification must be given of pro forma
transfers of control of domestic Section 214 authority that are
consummated as part of a bankruptcy proceeding. See 47 C.F.R. S:
63.03(d)(2).
See StanaCard, LLC, Joint International and Domestic Application for
Consent to the Transfer of Control, Attach. I at 5, WC Docket No. 12-18,
IBFS File No. ITC-T/C-20120116-00003 (filed Jan. 16, 2012) (Joint
Domestic/International Sec. 214 Application); Domestic Section 214
Application Filed for the Transfer of Control of StanaCard, LLC;
Streamlined Pleading Cycle Established, WC Docket No. 12-18, Public
Notice, 27 FCC Rcd 427 (Wireline Comp. Bur. 2012).
International Authorizations Granted, Public Notice, 25 FCC Rcd 1860 (Int.
Bur. 2010).
47 C.F.R. S: 63.01; see also Section 402 Implementation Order, supra note
3.
Letter from Cheng-yi Liu, Law Offices of Thomas K. Crowe, P.C., Counsel to
StanaCard, LLC, to Robert Krinsky, Attorney Advisor, Investigations and
Hearings Div., FCC Enforcement Bureau (filed Jan. 27, 2012) (on file in
EB-12-IH-0076).
See Joint Domestic/International Sec. 214 Application at 3; StanaCard,
LLC, Notification of the Pro Forma Transfer of Control of International
Section 214 Authority, IBFS File No. ITC-T/C-20120215-00051 at 1, 3 (filed
Feb. 15, 2012) (StanaCard Pro Forma Int'l Sec. 214 Application).
See StanaCard Pro Forma Int'l Sec. 214 Application at Attach. 1 (Answer to
Question 13).
Joint Domestic/International Sec. 214 Application, Attach. 1 at 3 (stating
that the October 23, 2010 transaction "effectively transferr[ed] control
of the company to [Ms.] Koroleva").
See Notification of Pro Forma Transfer of Control of International Section
214 Authorization, IBFS File No.: ITC-T/C-20120215-00051 (filed Feb. 15,
2012) (on file in EB-12-IH-0076) (notification of pro forma transfer of
control of international Section 214 authority held by StanaCard) (Pro
Forma Transfer of Control Notification).
See International Authorizations Granted - Section 214 Applications (47
C.F.R. 63.18); Section 310(b)(4) Requests, Public Notice, Report No.
TEL-01546, 27 FCC Rcd 1998, 2001 (Int'l Bur. 2012) (notice of grant of
IBFS File No. ITC-T/C-20120215-00051) (International Sec. 214 Pro Forma
Transfer Grant Public Notice).
See Joint Domestic/International Sec. 214 Application, Attach. at 2-3.
Id. at 3.
Joint Domestic/International Sec. 214 Application, supra note 9;
Streamlined International Applications Accepted for Filing, Section 214
Applications (47 C.F.R. S: 63.18), Public Notice, Report No. TEL-01545S,
2012 WL 524111 ( rel. Feb. 17, 2012) (accepting for filing StanaCard's
application for consent to transfer control of international Section 214
authority from Mr. Choupak to Ms. Koroleva); IBFS File No.
ITC-STA-20120116-00004 (filed Jan. 16, 2012) (Application for STA related
to StanaCard's application for consent to transfer control of
international Section 214 authority from Mr. Choupak to Ms. Koroleva) (on
file in EB-12-IH-0076); Domestic Section 214 Application for the Transfer
of Control of StanaCard, LLC, WC Docket No. 12-18 (filed Jan. 17, 2012) (
StanaCard's application for consent to transfer control of domestic
Section 214 authority from Mr. Choupak to Ms. Koroleva) (on file in
EB-12-IH-0076).
See International Authorizations Granted, Section 214 Applications (47
C.F.R. S: 63.18), Public Notice, Report No. TEL-01548, 27 FCC Rcd 2351,
2354 (Int'l Bur. 2012) (International Sec. 214 Grant PN) (notice of grant
of IBFS File No. ITC-T/C-20120116-00003); Domestic Section 214 Application
Filed for the Transfer of Control of StanaCard, LLC, Streamlined Pleading
Cycle Established, WC Docket No. 12-18, Public Notice, 27 FCC Rcd 427 n.2
(Wireline Comp. Bur. 2012).
See Domestic Section 214 Granted, Domestic Sec. 214 Application Filed for
the Transfer of Control of StanaCard, LLC, WC Docket No. 12-18, Public
Notice, 27 FCC Rcd 2381 (Wireline Comp. Bur. 2012); International Sec.
214 Grant PN, 27 FCC Rcd at 2354.
See 47 U.S.C. S: 503(b)(1)(B); 47 C.F.R. S: 1.80(a)(1).
47 U.S.C. S: 312(f)(1).
See H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982).
See, e.g., Southern California Broadcasting Co., Memorandum Opinion and
Order, 6 FCC Rcd 4387, 4388, para. 5 (1991) (Southern California
Broadcasting).
See, e.g., Callais Cablevision, Inc., Notice of Apparent Liability for
Monetary Forfeiture, 16 FCC Rcd 1359, 1362, para. 10 (2001) (Callais
Cablevision) (issuing an NAL for, inter alia, a cable television
operator's repeated violation of the cable signal leakage rules).
Southern California Broadcasting, 6 FCC Rcd at 4388, para. 5; Callais
Cablevision, 16 FCC Rcd at 1362, para. 9.
47 U.S.C. S: 503(b); 47 C.F.R. S: 1.80(f).
See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC Rcd 7589,
7591, para. 4 (2002).
See 47 C.F.R. S: 63.24(f).
See supra paragraph 6.
See Pro Forma Transfer of Control Notification, supra note 16;
International Sec. 214 Pro Forma Transfer Grant Public Notice, 27 FCC Rcd
at 2001; see also 47 C.F.R. S: 63.24(d) (defining pro forma assignments
and transfers of control as transactions that "do not result in a change
in the actual controlling party. . . .").
Id.
47 U.S.C. S: 214; 47 C.F.R. S:S: 63.03, 63.04, 63.18, 63.24; see also
supra paragraph 2.
See supra paragraph 7.
Id.
47 U.S.C. S: 503(b)(1)(B).
47 U.S.C. S: 503(b)(2)(B); see also 47 C.F.R. S: 1.80(b)(2). The
Commission has amended Section 1.80(b)(2) of the Rules three times to
increase the maximum forfeiture amounts, in accordance with the inflation
adjustment requirements contained in the Federal Civil Penalties Inflation
Adjustment Act of 1990, 28 U.S.C. S: 2461 note, as amended by the Debt
Collection Improvement Act of 1996, 31 U.S.C. S: 3701 note. The most
recent inflation adjustment took effect September 2, 2008 and applies to
violations that occur after that date. See Amendment of Section 1.80(b) of
the Commission's Rules, Adjustment of Forfeiture Maxima to Reflect
Inflation, Order, 23 FCC Rcd 9845 (2008) (adjusting the maximum statutory
amounts for common carriers from $130,000/$1,325,000 to
$150,000/$1,500,000).
See 47 U.S.C. S: 503(b)(2)(E); see also 47 C.F.R. S: 1.80(b)(6), Note to
paragraph (b)(6): Guidelines for Assessing Forfeitures.
See 47 C.F.R. S: 1.80(b)(6), Note to paragraph (b)(6).
See id.
See Kajeet Inc. and Kajeet/Airlink, LLC, Notice of Apparent Liability for
Forfeiture and Order, 26 FCC Rcd 16684, 16697, para. 29 (2011) (Kajeet
NAL).
See supra paragraph 7.
See 47 U.S.C. S: 503(b)(2)(E); Kajeet NAL, 26 FCC Rcd at 16697, para. 29
(upwardly adjusting the $8,000 base forfeiture to $16,000 in response to a
two-year delay in seeking Commission approval of a substantial
unauthorized assignment of international Section 214 authority).
47 U.S.C. S: 503(b).
47 C.F.R. S: 1.80.
An FCC Form 159 and detailed instructions for completing the form may be
obtained at http://www.fcc.gov/Forms/Form159/159.pdf.
See 47 C.F.R. S: 1.1914.
See 47 C.F.R. S:S: 1.80(f)(3), 1.16.
Federal Communications Commission DA 13-14
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Federal Communications Commission DA 13-14