← Governance framework
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
Anchored by content hashissued 2026-07-29
Payload hash
ddab1cd80484a069a96f303ba90c6921cfba4f6e92cc63fff15e4972b67ce094SHA-256 digest of the receipt content
Issuer AID
EP1_FGkcwfHAuih6VUzv9kgAVBvvSoaswSUao61lkxhEParty that issued this receipt
ImpactMiles handle
audit:governance:ddab1cd80484a069This receipt is anchored by content hash. A resolvable credential SAID is not available for this record.
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.