Why we monitor cumulative auto-reload spend

Like every regulated payments platform, ReloadCard has anti-money-laundering ("AML") obligations. One of the things that means in practice is keeping an eye on cumulative gift-card top-ups across long time windows. Here's what we actually do, why, and why it almost certainly doesn't affect you.

What we monitor

Once a day, an automated review runs across every active auto-reload subscription on the platform. It rolls up the total Stripe-funded reloads each consumer has made across the entire ReloadCard network over the trailing 12 months — every merchant they auto-reload at, summed together. If that aggregate total crosses USD $10,000 for a single consumer, an internal compliance event is logged for human review.

That's it. The review is automated, runs at 2 AM UTC, and doesn't pause, slow, or interfere with your auto-reload. Charges keep running on schedule.

What happens after a flag is raised

A real person on our compliance team picks up the flag. Depending on what they see, one of three things happens:

1. Most common — they close the case immediately. Long-running, high-spend customers at a coffee chain, a salon, or a fitness studio look exactly like a long-running, high-spend customer at a coffee chain, a salon, or a fitness studio. The flag is logged for record-keeping and we move on.

1. They ask for additional KYC. If we don't already have enhanced identity verification on file and the spend pattern is genuinely unusual, we may ask you to complete a quick ID-and-address verification step in your wallet. This brings us into line with the same enhanced-due-diligence rules every regulated payments business has.

1. Very rarely — we file a SAR. A "Suspicious Activity Report" is the formal mechanism we use to escalate to FinCEN if a pattern looks consistent with money laundering. We're legally required not to tell you when we file one, but we want to be transparent that the mechanism exists.

In all three cases your auto-reload keeps running unless the compliance team explicitly pauses it — and that's reserved for the third-bucket cases.

Why $10K?

The $10,000 threshold mirrors thresholds used elsewhere in US payments regulation (the Bank Secrecy Act's CTR threshold, IRS Form 8300 reporting). It's high enough that it doesn't catch normal high-spend retail behaviour — a customer reloading $250 every week only crosses it after a full year — but low enough to give us early visibility on patterns that would otherwise grow unchecked.

If you're a $250-per-week-at-your-favourite-cafe customer, you may eventually trip the flag, the case gets opened, the compliance reviewer looks at it, says "yep, that's a coffee customer," and closes it. You won't hear about it.

What we don't do

• We don't share this data with merchants. A merchant cannot see "this consumer has spent $X across the network." Each merchant only sees their own customers.
• We don't share with advertisers. No third party gets access to AML monitoring data.
• We don't use this for marketing. It's a compliance review, not a segmentation pipeline.
• We don't slow down or rate-limit your auto-reload because of it. Charges keep running.

Related

• Auto-reload cancellation rights — cancel anytime, no fees
• Privacy Policy — what we collect, share, and retain
• Terms of Service §5.8 — full auto-reload contract
• Auto-reload FAQ — ten common questions