Introduction
This Anti-Money Laundering (AML), Know Your Customer (KYC), and Sanctions Policy (the "Policy") outlines the guidelines and procedures implemented by RaiseBerry, LLC ("the Company") to prevent money laundering, identify potential risks associated with fraudulent activities, and comply with applicable sanctions regulations. The Policy applies to all users, including verified 501(c)(3) organizations and US-based schools, utilizing our online fundraising platform.
Definitions
2.1. AML: Anti-Money Laundering refers to the set of laws, regulations, and procedures implemented to prevent the conversion of illegally obtained funds into legitimate assets.
2.2. KYC: Know Your Customer refers to the process of verifying the identity and assessing the legitimacy of individuals or organizations to mitigate potential risks associated with fraudulent activities.
2.3. Sanctions: Sanctions refer to economic or trade restrictions imposed by governments or international bodies to enforce international law, protect national security, or promote foreign policy objectives.
Compliance with Applicable Laws and Regulations
3.1. The Company is committed to complying with all relevant AML, KYC, and Sanctions laws, regulations, and guidelines in the jurisdictions where it operates. We maintain an understanding of applicable legal requirements and strive to update our policies and procedures accordingly.
3.2. The Company's operations are limited to verified 501(c)(3) organizations and US-based schools. We require all users to provide valid documentation and information to establish their eligibility.
Customer Due Diligence (CDD)
4.1. The Company follows a risk-based approach to customer due diligence. We conduct thorough verification of the identity and legitimacy of all users to assess the potential risk of money laundering or fraudulent activities.
4.2. When onboarding new users, the Company collects and verifies the following information:
a. For verified 501(c)(3) organizations:
- Official organization name
- EIN (Employer Identification Number)
- Contact details of authorized representatives
- Proof of tax-exempt status
b. For US-based schools and affiliated organizations:
- Official school name
- School tax identification number
- Contact details of authorized representatives
4.3. The Company may employ third-party services and databases to verify the provided information and conduct additional checks, including but not limited to, sanctions lists, politically exposed persons (PEP), and adverse media checks.
4.4. The Company relies on Stripe's KYC function for the onboarding of users and the verification of their identity. The Company considers Stripe's KYC process as an integral part of its own KYC process, and the information provided to Stripe during the creation of a Stripe connected account is utilized for user verification on our platform.
4.5. The Company reserves the right to request additional information or documents for enhanced due diligence (EDD) purposes, particularly in cases where higher-risk factors are identified or when transactions meet specific thresholds.
Monitoring and Reporting
5.1. The Company maintains ongoing monitoring of user activities for the detection of suspicious transactions, money laundering, or fraudulent activities.
5.2. In case of any suspicious activity or potential breach of any of these regulations, the Company's designated or acting compliance officer shall promptly investigate and report the findings to the appropriate authorities as required by law.
Training and Awareness
6.1. The Company provides regular training to its employees regarding AML, KYC, and Sanctions regulations to ensure they are aware of their obligations, understand the potential risks, and know how to report suspicious activities.
Record-Keeping
7.1. The Company maintains accurate and up-to-date records of all user information, verification documents, and transaction details in compliance with applicable laws and regulations.
7.2. The retention period for records will be determined based on legal requirements, industry standards, and the Company's internal policies.
Non-Tolerance of Sanctions Violations
8.1. The Company strictly prohibits the use of its platform for any activities that violate sanctions laws or regulations.
8.2. If the Company becomes aware of any user engaging in prohibited activities or conducting transactions with sanctioned individuals, entities, or countries, appropriate actions will be taken, which may include suspension or termination of the user's account and reporting to relevant authorities.
Cooperation with Regulatory Authorities
9.1. The Company is committed to cooperating with regulatory authorities, law enforcement agencies, and other relevant entities in matters related to AML, KYC, and Sanctions compliance.
9.2. The Company will respond to information requests, subpoenas, or other lawful demands for user information or transaction details from authorized entities, provided such requests are consistent with applicable laws and regulations.
Policy Review and Updates
10.1. The Company will periodically review and update this AML/KYC/Sanctions Policy to ensure its effectiveness, adequacy, and compliance with changing laws, regulations, and industry best practices.
10.2. Users will be notified of any material changes to the Policy, and their continued use of the platform will be considered as acceptance of the updated terms.
