Last week, the FCC issued a Notice of Apparent Liability (NAL) to StanaCard, LLC, a licensed provider of, among other things, prepaid international telecommunications services.  StanaCard today markets its services under the brand name “Keku.”  The NAL proposed to fine StanaCard $21,000 for (1) failing to notify the FCC of a pro forma change in control of the company; and (2) failing to secure FCC approval before consummating substantial transfers of control on two previous occasions.  The FCC’s rules require telecommunications licensees to secure prior approval before consummating any transfer of control and to notify the FCC within 30 days of consummating any pro forma change in control.  The proposed fine was based on the $1000 base forfeiture for consummating a pro forma change in control without notification, plus the $8000 base forfeiture amount for each unauthorized substantial transfer of control, which the FCC multiplied by two to account for the two occasions in which StanaCard failed to secure the necessary authorization.  The FCC then adjusted the resulting $16,000 figure upward to a total of $20,000 to account for a six-monthly delay before StanaCard self-reported its failure to the FCC.  StanaCard has 30 days to dispute the total proposed fine of $21,000 or pay it.