Disclaimer: I don’t work for CVS or Vanilla Reload/Incomm, nor do I actually know what I’m talking about. But I can read, and I’ve talked to a couple of friends who have experience with BSA/AML requirements, so I think I can make some educated guesses.
The other day at CVS, the person in front of me was buying two Vanilla Reload cards. While I normally just load $500 onto Vanilla Reloads when I buy them, the person in front of me loaded $500 onto one and $490 on the other. Presumably, this was to avoid having his driver’s license swiped by CVS, as they somewhat recently instituted this requirement for Vanilla Reload purchases totaling more than $1000. But should you care if CVS takes your driver’s license and swipes it?
I believe the short answer is no. Nothing bad happens when they take your ID. You don’t get blacklisted, you don’t get investigated by the FBI, and you won’t spontaneously catch on fire.
Some people worry that scanning their ID means that they might be subject to a scary-sounding thing called a Suspicious Activity Report or SAR, which is a report made by a financial institution to FinCEN when there’s suspicious or potentially suspicious activity going on. What counts as suspicious? 1) Funds potentially derived from illegal activities; 2) transactions designed to evade the requirements of the Bank Secrecy Act; and 3) transactions that don’t have an apparent business or lawful purpose.
Buying large amounts of Vanilla Reloads could potentially be suspicious because there’s not really an apparent business purpose for doing so, but honestly, given the monthly reload limits on Bluebird, it’s unlikely that you’re buying enough VRs per month to be all that interesting. But what’s more likely to be considered suspicious is structuring your transactions to specifically evade the ID swiping requirement or else refusing to swipe your ID if asked for it.
Regardless, even if you do get a SAR filed on you, for one, you won’t know it happened, since it’s a federal criminal offense for anyone to disclose a SAR filing to the entity that it’s filed on, but two, nothing bad actually happens. Unless you’re involved in other illegal activities and you’re actually buying the Vanilla Reloads for nefarious reasons, you have nothing to worry about. The SAR will get filed and likely never be read ever again.
As I stated in my disclaimer, my conclusions could be completely wrong, but based on what I’ve learned about SARs, you don’t have to worry about CVS taking your ID and swiping it. Now, SARS, on the other hand…