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Financial & Anti-Fraud

Anti-Money-Laundering and Counter-Terrorism Financing Policy

Risk-based controls to prevent misuse of the ImpactMiles platform for money laundering or terrorism financing.

Version
v1.0
Effective
2026-07-19
Last reviewed
2026-07-19
Next review
2027-07-19
Owner
Compliance Lead
Approver
Board of Trustees

Applies to

  • All Sponsor and Charity organisations
  • All donation and sponsorship flows

Jurisdictions

  • Hong Kong (PDPO, IRD s.88)
  • United Kingdom (UK GDPR, DPA 2018)
  • European Union (GDPR)
  • Singapore (PDPA)
  • Australia (Privacy Act 1988)
  • Japan (APPI)
  • Wider APAC per country taxonomy

How this is applied in-product

  • Veraf.ai KYB and AML checks triggered from the admin verifications console
  • Risk score persisted on the organisation profile
  • Onboarding blocked from progression until mandatory evidence is captured

1. Customer Due Diligence

  • Standard due diligence for all onboarded organisations via Veraf.ai.
  • Enhanced due diligence for organisations in higher-risk jurisdictions, higher-risk sectors, or with PEP linkage.
  • Ongoing monitoring with periodic re-screening.

2. Transaction Monitoring

  • Threshold and pattern rules applied to donation and sponsorship flows.
  • Suspicious Activity Reports lodged with the relevant Financial Intelligence Unit as required by law.
  • Records retained for 5 years.

3. Sanctions

Organisations are screened against UN, EU, UK, US OFAC and HKMA sanctions lists. Positive matches block onboarding pending manual review.

Questions or concerns about this policy? Contact the DPO.

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