Federal Communications Commission DA 12-8
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
StanaCard, LLC 
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File No.:  EB-09-IH-1946
Acct. No.:  201232080014
FRN:  0018463380
ORDER
Adopted:  February 22, 2012 Released:  February 22, 2012
By the Chief, Enforcement Bureau:
1. In this Order, we adopt the attached Consent Decree entered between the Enforcement 
Bureau (Bureau) of the Federal Communications Commission (Commission) and StanaCard, LLC 
(StanaCard).  The Consent Decree terminates an investigation by the Bureau against StanaCard for 
possible violations of Sections 214 and 225 of the Communications Act of 1934, as amended (Act)1 and 
Sections 63.18, 64.604(c)(5)(iii)(A), and 64.1195(a) of the Commission’s rules (Rules)2 concerning 
authorization to provide facilities-based and resold international common carrier communications 
services, contributions to the Telecommunications Relay Services Fund, and registration with the 
Commission. 
2. A copy of the Consent Decree negotiated by the Bureau and StanaCard is attached hereto 
and incorporated herein by reference.
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
investigation.
4. In the absence of material new evidence relating to this matter, we conclude that our 
investigation raises no substantial or material questions of fact as to whether StanaCard possesses the 
basic qualifications, including those related to character, to hold or obtain any Commission license or 
authorization.
5. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act3 and Sections 
0.111 and 0.311 of the Rules,4 the Consent Decree attached to this Order IS ADOPTED.
  
1 47 U.S.C. §§ 214, 225.
2 47 C.F.R. §§ 63.18, 64.604(c)(5)(iii)(A), 64.1195(a).
3 47 U.S.C. § 154(i).
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6. IT IS FURTHER ORDERED that the above-captioned investigation IS 
TERMINATED.
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by certified mail, return receipt requested, to Mr. Cheng Yi Liu, Esq., Counsel to StanaCard, LLC, 
Law Offices of Thomas K. Crowe, P.C., 1250 24th Street, NW, Suite 300, Washington DC 20037.
FEDERAL COMMUNICATIONS COMMISSION
P. Michele Ellison
Chief, Enforcement Bureau
    
4 47 C.F.R. §§ 0.111, 0.311.
Federal Communications Commission DA 12-8
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
StanaCard, LLC 
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)
)
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File No.:  EB-09-IH-1946
Acct. No.:  201232080014
FRN:  0018463380
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and StanaCard, 
LLC, by their authorized representatives, hereby enter into this Consent Decree for the purpose of 
terminating the Bureau’s investigation into whether the Company violated Sections 214 and 225 of the 
Communications Act of 1934, as amended,1 and Sections 63.18, 64.604(c)(5)(iii)(A), and 64.1195(a) of 
the Commission’s rules,2 concerning authorization to provide facilities-based and resold international 
common carrier communications services, contributions to the Telecommunications Relay Services Fund, 
and registration with the Commission.
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq.
(b) “Adopting Order” means an Order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission.
(d) “Commission” and “FCC” mean the Federal Communications Commission and all 
of its bureaus and offices.  
(e) “Communications Laws” means collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which StanaCard is 
subject by virtue of its business activities.
(f) “Compliance Officer” means the individual designated as the person responsible for 
administration of the Compliance Plan.
  
1 47 U.S.C. §§ 214, 225.
2 47 C.F.R. §§ 63.18, 64.604(c)(5)(iii)(A), 64.1195(a).
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(g) “Compliance Plan” means the compliance obligations and program described in this 
Consent Decree at paragraph 12.
(h) “Effective Date” means the date on which the Commission releases the Adopting 
Order.
(i) “Investigation” means the investigation commenced by the Bureau in response to 
StanaCard’s disclosure e-mail of August 20, 2009,3 regarding the Company’s 
compliance with Section 214 of the Act and Part 63 of the Rules concerning 
StanaCard’s obligation to obtain Commission authorization before providing 
facilities-based or resold international common carrier services, compliance with 
Part 64 of the Rules regarding registration by interstate telecommunications carriers, 
and compliance with Section 225 of the Act and Part 64 of the Rules regarding 
interstate telecommunication carrier contributions to the TRS Fund.4
(j) “Parties” means StanaCard and the Bureau, each of which is a “Party.”
(k) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.
(l) “StanaCard” or the “Company” means StanaCard, LLC and its predecessors-in-
interest and successors-in-interest.
(m) “TRS Fund” means Telecommunications Relay Services Fund.
II. BACKGROUND
3. Section 214(a) of the Act prohibits any carrier from constructing, extending, acquiring, or 
operating any line, and from engaging in transmission through any such line, without first obtaining a 
certificate of authorization from the Commission.5 While the Commission has granted “blanket” Section 
214 authority to carriers providing domestic service,6 meaning that such carriers need not apply to the 
Commission for such authority before providing domestic service,7 the Commission has not done the 
same for providers of international telecommunications services.  Section 63.18 of the Rules requires any 
  
3 E-mail from Thomas K. Crowe, Partner, Law Offices of Thomas K. Crowe, P.C., Counsel to StanaCard, LLC, to 
Trent B. Harkrader, Deputy Chief, Investigations & Hearings Division, FCC Enforcement Bureau (Aug. 20, 2009, 
17:50 EDT).
4 47 U.S.C. §§ 214, 225; 47 C.F.R. Parts 63-64.
5 47 U.S.C. § 214(a).  
6 47 C.F.R. § 63.01(a) (“Any party that would be a domestic interstate communications common carrier is 
authorized to provide domestic, interstate services to any domestic point and to construct or operate any domestic 
transmission line as long as it obtains all necessary authorizations from the Commission for use of radio 
frequencies.”).  
7 See 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 & Order in AAD File No. 98-43, 14 FCC Rcd 11364, para. 2 (1999) 
(“Specifically, we grant ‘blanket’ entry certification to all carriers seeking to construct, operate, or engage in 
transmission over domestic lines of communication, to the extent such authority is required under the statute.”).
Federal Communications Commission DA 12-8
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carrier that seeks Section 214 authority “for provision of common carrier communication services 
between the United States, its territories or possessions, and a foreign point” to request such authority by 
application.8 The application requirement applies to carriers that provide facilities-based service or that 
resell the service of another authorized carrier.9
4. The Commission has been charged by Congress to establish, administer and maintain 
various telecommunications regulatory programs, and to fund these programs through assessments on the 
telecommunications providers that benefit from them.  To accomplish these goals, the Commission 
established “a central repository of key facts about carriers” through which it monitors the entry and 
operation of interstate telecommunications providers to ensure, among other things, that they are qualified 
to provide telecommunications service, do not engage in fraud, and do not evade oversight.10 The Rules 
require that upon entry or anticipated entry into interstate telecommunications markets, 
telecommunications carriers register by submitting information on FCC Form 499-A, also known as the 
Annual Telecommunications Reporting Worksheet (Annual Worksheet or Form 499-A).11
5. Section 225(b)(1) of the Act, which codifies Title IV of the Americans with Disabilities 
Act of 1990, directs the Commission to “ensure that interstate and intrastate telecommunications relay
services are available, to the extent possible and in the most efficient manner, to hearing-impaired and 
speech-impaired individuals in the United States.”12 To that end, the Commission established the TRS 
Fund to reimburse TRS providers for the costs of providing interstate telecommunications relay 
services.13 Pursuant to Section 64.604(c)(5)(iii)(A) of the Rules, every provider of interstate 
telecommunications services must contribute to the TRS Fund based upon its end-user revenues.14  
6. StanaCard, a Delaware limited liability company, is a resale provider primarily of 
international pre-paid telecommunications services.  On August 20, 2009, StanaCard disclosed to the 
Bureau that it apparently had failed to comply with Sections 214 of the Act15 and Sections 63.18 and 
64.1195(a) of the Rules16 because it had failed to obtain authorization for the provision of international 
  
8 47 C.F.R. § 63.18.  
9 Id. § 63.18(e)(1)-(2).  
10 See Implementation of the Subscriber Carrier Selection Changes Provisions of the Telecommunications Act of 
1996, Third Report and Order and Second Order on Reconsideration, 15 FCC Rcd 15996, 16024–26, paras. 59–62 
(2000) (Carrier Selection Order).    
11 47 C.F.R. § 64.1195.  See also FCC Form 499-A Telecommunications Reporting Worksheet ? Annual Filing, 
available at http://transition.fcc.gov/Forms/Form499-A/499a-2008.pdf (February 2008).  
12 47 U.S.C. § 225(b)(1).
13 See Telecommunications Relay Services and the Americans with Disabilities Act of 1990, Third Report and Order, 
8 FCC Rcd 5300, 5301, para. 7 (1993).  Telecommunications relay services enable persons with hearing and speech 
disabilities to communicate by telephone with voice-telephone users.  Such services provide telephone access to a 
significant number of Americans who, without it, might not be able to make calls to or receive calls from voice-
telephone users.  See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, Report and Order, 15 FCC Rcd 5140, 5143 ¶ 5 (2000).  See also
64.601(a)(21)(definition of “telecommunications relay services”).
14 47 C.F.R. § 64.604(c)(5)(iii)(A).
15 47 U.S.C. §§ 214, 225.
16 47 C.F.R. §§ 63.18, 64.604(c)(5)(iii)(A), 64.1195(a).
Federal Communications Commission DA 12-8
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common carrier communications services, and it had not timely registered with the Commission.17 In 
response, the Bureau launched an investigation.  
7. StanaCard registered with the Commission in February 2009, 23 months after it 
commenced service.  The Company made its 2008 contribution to the TRS Fund approximately nine 
months late, and filed an application for international Section 214 authorization 27 months after it had 
started offering international service.18 On February 01, 2010, the International Bureau of the 
Commission granted StanaCard’s application for the provision of global facilities–based and global resale 
services.19
III. TERMS OF AGREEMENT
8. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
subject to final approval by the Bureau by incorporation of such provisions by reference in the Adopting 
Order.
9. Jurisdiction.  StanaCard agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
10. Effective Date:  Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date.  Upon release, the Adopting Order and this Consent Decree shall have the 
same force and effect as any other order of the Bureau.  Any violation of the Adopting Order or of the 
terms of this Consent Decree shall constitute a separate violation of a Bureau order, entitling the Bureau
to exercise any rights and remedies attendant to the enforcement of a Commission order.  
11. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for the termination of the Investigation, StanaCard agrees to 
the terms, conditions, and procedures contained herein.  The Bureau further agrees that in the absence of 
new material evidence, the Bureau will not use the facts developed in the Investigation through the 
Effective Date of the Consent Decree, or the existence of this Consent Decree, to institute, on its own 
motion, any new proceeding, formal or informal, or take any action on its own motion against StanaCard 
concerning the matters that were the subject of the Investigation.  The Bureau also agrees that in the 
absence of new material evidence it will not use the facts developed in the Investigation through the 
Effective Date of this Consent Decree, or the existence of this Consent Decree, to institute on its own 
motion any proceeding, formal or informal, or take any action on its own motion against StanaCard with 
respect to StanaCard’s basic qualifications, including its character qualifications, to be a Commission 
licensee or hold Commission authorizations.  
12. Compliance Plan.  StanaCard agrees that it will implement a comprehensive Compliance 
Plan for the purpose of ensuring its compliance with the Communications Laws.  The Compliance Plan 
shall include, at a minimum, the following components:
  
17 See supra note 3.
18 See IBFS File No. ITC-214-20090624-00301.
19 International Authorizations Granted, Public Notice, 25 FCC Rcd 1860 (FCC/IB 2010).  During the pendency of 
this application for international Section 214 authorization, StanaCard was granted special temporary authority to 
provide international service.  See IBFS File Nos. ITC-STA-20090625-00304, ITC-STA-20090902-00407, ITC-
STA-20091106-00467, ITC-STA-20100105-00005.
Federal Communications Commission DA 12-8
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a) Compliance Officer.  StanaCard shall designate a Compliance Officer, as defined in 
paragraph two of this Consent Decree, within thirty (30) calendar days of the 
Effective Date.  The Compliance Officer shall administer the Compliance Plan, 
supervise StanaCard’s compliance with the Communications Laws, and serve as the 
point of contact on behalf of StanaCard for all FCC-related compliance matters.
b) Compliance Manual.  Within sixty (60) calendar days of the Effective Date, the 
Compliance Officer shall develop and distribute a Compliance Manual to StanaCard
employees and others who perform StanaCard’s federal regulatory reporting and 
compliance-related tasks, all of whom shall follow the procedures detailed in the 
Compliance Manual.  The Compliance Manual will include at a minimum (i) an 
overview of the Commission’s requirements, including the need for international 
Section 214 authorization prior to providing international common carrier 
telecommunications services; (ii) a description of the regulatory requirements 
applicable to the accurate and timely contributions to the TRS Fund pursuant to 
Section 225 of the Act and Section 64.604 of the Rules; and (iii) instructions 
regarding the Commission’s registration requirement pursuant to Section 64.1195 of 
the Rules, including the obligation to notify the Commission of any changes to the 
information required as part of registration.20  
c) Compliance Training Program.  Within ninety (90) calendar days of the Effective 
Date, and annually thereafter, StanaCard shall implement and conduct a training 
program for all employees who perform duties at StanaCard that trigger or may 
trigger compliance-related responsibilities.  StanaCard shall ensure that training and 
compliance materials are provided to new and reassigned employees who are 
responsible for fulfilling those obligations within the first thirty (30) calendar days of 
employment or reassignment.
d) Review and Monitoring.  StanaCard shall review the Compliance Manual and 
Compliance Training Program at least annually to ensure they are maintained in a 
proper manner and continue to address StanaCard’s compliance with federal 
regulatory reporting obligations.  StanaCard shall update the Compliance Manual and 
Compliance Training Program in the event of changes and/or additions to the 
Communications Laws.
e) Compliance Reports.  StanaCard shall file compliance reports with the Commission 
ninety (90) calendar days after the Effective Date, twelve (12) months after the 
Effective Date, twenty-four (24) months after the Effective Date, and upon expiration 
of this Compliance Plan, thirty-six (36) months after the Effective Date.  Each 
compliance report shall include a compliance certificate from the Compliance 
Officer, as an agent of and on behalf of the Company, stating that the Compliance 
Officer has personal knowledge that the Company:  (i) has established operating 
procedures intended to ensure compliance with the terms and conditions of this 
Consent Decree and Sections 214 and 225 of the Act21 and Sections 63.18, 
  
20 47 C.F.R. § 64.1195(g).
21 47 U.S.C. §§ 214, 225.
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64.604(c)(5)(iii)(A), and 64.1195(a) of the Rules,22 together with an accompanying 
statement explaining the basis for the Compliance Officer’s certification; (ii) has 
been utilizing those procedures since the previous Compliance Report was submitted; 
and (iii) is not aware of any instances of non-compliance.  The certification must 
comply with Section 1.16 of the Rules23 and be subscribed to as true under penalty of 
perjury in substantially the form set forth therein.  If the Compliance Officer cannot 
provide the requisite certification, the Compliance Officer, as an agent of and on 
behalf of the Company, shall provide the Commission with a detailed explanation of:  
(i) any instances of non-compliance with this Consent Decree and Sections 214 and 
225 of the Act24 and Sections 63.18, 64.604(c)(5)(iii)(A), and 64.1195(a) of the 
Rules25, and (ii) the steps that the Company has taken or will take to remedy each 
instance of non-compliance and ensure future compliance, and the schedule on which 
proposed remedial actions will be taken.  All compliance reports shall be submitted 
to the Chief, Investigations and Hearings Division, Enforcement Bureau, Federal 
Communications Commission, Room 4-C330, 445 12th Street, S.W., Washington, 
D.C. 20554, with a copy submitted electronically to Theresa Z. Cavanaugh at 
Terry.Cavanaugh@fcc.gov, Pamela S. Kane at Pamela.Kane@fcc.gov and to Robert 
B. Krinsky at Robert.Krinsky@fcc.gov.
f) Reporting Non-Compliance.  StanaCard shall report any non-compliance with this 
Consent Decree, Sections 214 and 225 of the Act, Parts 63 and 64 of the Rules, and 
related Commission orders to the Bureau within 30 calendar days after the discovery 
of non-compliance.
g) Termination Date of Compliance Plan.  The requirements relating to the 
Compliance Plan shall expire three (3) years after the Effective Date, unless stated 
otherwise.
13. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
Section 208 of the Act against StanaCard or its affiliates for alleged violations of the Act, or for any other 
type of alleged misconduct, regardless of when such misconduct took place.  The Commission’s 
adjudication of any such complaint will be based solely on the record developed in that proceeding.  
Except as expressly provided in this Consent Decree, this Consent Decree shall not prevent the 
Commission from investigating new evidence of noncompliance by StanaCard with the Communications 
Laws.
14. Voluntary Contribution.  StanaCard agrees that it will make a voluntary contribution to 
the United States Treasury in the amount of one hundred thirty-six thousand dollars ($136,000.00), with 
an initial payment of thirty-six thousand dollars ($36,000.00) and four (4) quarterly installment payments 
of twenty-five thousand dollars ($25,000.00) paid over the course of a twelve-month period.  The initial 
payment of $36,000.00 shall be made within thirty (30) calendar days of the Effective Date.  The first 
$25,000 installment shall be made within one hundred twenty (120) calendar days of the Effective Date, 
  
22 47 C.F.R. §§ 63.18, 64.604(c)(5)(iii)(A), 64.1195(a).
23 Id. § 1.16.
24 47 U.S.C. §§ 214, 225.
25 47 C.F.R. §§ 63.18, 64.604(c)(5)(iii)(A), 64.1195(a).
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the second $25,000 installment shall be made within two hundred ten (210) calendar days of the Effective 
Date, the third $25,000 installment shall be made within three hundred (300) calendar days of the 
Effective Date, and the fourth $25,000 installment shall be made within three hundred ninety (390) 
calendar days of the Effective Date. The payments must include the Account Number and FRN 
referenced in the caption to the Adopting Order.  Payments by check or money Order may be mailed to 
the Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  Payments by 
overnight mail may be sent to U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 
Convention Plaza, St. Louis, MO 63101.  Payments by wire transfer may be made to ABA Number 
021030004, receiving bank TREAS/NYC, and account number 27000001.  For payments by credit card, 
an 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).  StanaCard shall send electronic notification of each installment 
payment to Robert B. Krinsky at Robert.Krinsky@fcc.gov on the dates payments are made. 
15. Waivers.  StanaCard waives any and all rights it may have to seek administrative or 
judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest the validity of this 
Consent Decree and the Adopting Order, provided the Bureau issues an Adopting Order, adopting the 
Consent Decree without change, addition, modification, or deletion.  StanaCard shall retain the right to 
challenge Commission interpretation of the Consent Decree or any terms contained herein.  If either Party 
(or the United States on behalf of the Commission) brings a judicial action to enforce the terms of the 
Adopting Order, neither StanaCard nor the Commission shall contest the validity of the Consent Decree 
or the Adopting Order, and StanaCard shall waive any statutory right to a trial de novo.  StanaCard hereby 
agrees to waive any claims it may have under the Equal Access to Justice Act, 5 U.S.C. § 504, and         
47 C.F.R. § 1.1501 et seq., relating to the matters addressed in this Consent Decree.
16. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.
17. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent Rule or order adopted by the Commission (except an order 
specifically intended to revise the terms of this Consent Decree to which StanaCard does not expressly 
consent) that provision will be superseded by such Commission Rule or Order.
18. Successors and Assigns.  StanaCard agrees that the provisions of this Consent Decree 
shall be binding on its successors, assigns, and transferees.  
19. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the matters set forth herein.  The Parties 
further agree that this Consent Decree does not constitute either an adjudication on the merits or a factual 
or legal finding or determination regarding any compliance or noncompliance with the requirements of 
the Communications Laws.
20. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties.
21. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree.
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22. Authorized Representative. The individual signing this Consent Decree on behalf of 
StanaCard represents and warrants that he is authorized by StanaCard to execute this Consent Decree and 
to bind StanaCard to the obligations set forth herein.  The FCC signatory represents that she is signing 
this agreement in her official capacity and that she is authorized to execute this Consent Decree.
23. Counterparts.  This Consent Decree may be signed in any number of counterparts 
(including by facsimile), each of which, when executed and delivered, shall be an original, and all of 
which counterparts together shall constitute one and the same fully executed instrument.
________________________________
P. Michele Ellison
Chief
Enforcement Bureau 
Federal Communications Commission
________________________________
Date
________________________________
Manlio Carrelli
Chief Executive Officer
StanaCard, LLC
________________________________
Date