Anti-Money Laundering and Counter-Terrorist
Financing Policy
Effective date: 1 August 2026. Donaify applies a risk-based approach to financial crime prevention.
This public summary describes Donaify's intended compliance framework. Internal procedures, risk rules,
thresholds, and investigation methods are confidential and may be more detailed.
1. Purpose and scope
Donaify seeks to prevent the platform from being used for money laundering, terrorist financing, sanctions
evasion, fraud, trafficking, corruption, tax crime, or other unlawful activity. This Policy applies to organizers,
beneficiaries, representatives, donors, payout recipients, campaigns, donations, refunds, and payouts.
2. Risk-based controls
Customer and organization identity verification.
Beneficial ownership and authority checks where relevant.
Campaign-purpose and supporting-document review.
Sanctions, politically exposed person, and adverse-media screening.
Transaction, velocity, device, geography, refund, chargeback, and payout monitoring.
Enhanced due diligence for higher-risk users, countries, causes, amounts, or patterns.
Holds, reserves, rejection, closure, reporting, and record preservation where appropriate.
3. Customer due diligence
Before publication or payout, and at other times, we may collect and verify identity, date of birth, address,
nationality, organization registration, tax information, ownership or control, representative authority, bank
ownership, campaign evidence, source of funds, source of wealth, and intended use of funds.
4. Enhanced due diligence
Additional review may apply to unusually large or rapid activity, complex ownership, high-risk jurisdictions,
politically exposed persons, adverse media, third-party funding, inconsistent information, unusual refunds,
multiple linked accounts, sudden changes in payout destination, or activity lacking a clear lawful purpose.
5. Sanctions and prohibited jurisdictions
We do not knowingly make services available to sanctioned persons, entities, organizations, or
comprehensively restricted jurisdictions. Screening may use official and commercial lists and may apply to
users, owners, representatives, beneficiaries, banks, and transaction counterparties.
6. Monitoring and investigations
We may review transactions before or after processing and may request evidence such as invoices, medical
documents, beneficiary consent, bank records, organization records, source-of-funds evidence, or an
explanation of transaction patterns. Funds and payouts may be delayed while a review is pending.
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7. Suspicious activity and cooperation
Where legally required or reasonably necessary, we may reject or freeze activity, preserve records, cooperate
with banks, processors, card networks, courts, regulators, or law enforcement, and make reports through
appropriate legal channels. We may be prohibited from telling a user that a report or investigation exists.
8. Recordkeeping
Identity, account, campaign, transaction, payout, screening, investigation, and communication records are
retained for periods required by applicable law and provider obligations and as reasonably necessary to
manage fraud, disputes, taxes, and legal claims.
9. Staff responsibility and training
The Company assigns responsibility for compliance oversight, restricts access to sensitive records, and
provides role-appropriate guidance or training to personnel involved in campaign review, support, payments,
refunds, and payouts.
10. User obligations
Provide complete and truthful information and documents.
Do not structure, split, disguise, route, or layer transactions to avoid controls.
Do not use another person's identity, bank account, card, or organization without lawful authority.
Notify Donaify of material changes in ownership, control, campaign purpose, beneficiary, or payout
account.
Cooperate promptly with reasonable verification and investigation requests.
11. Contact
Compliance concerns may be reported to support@donaify.com. Do not use email to send full card details or
unnecessary sensitive documents unless requested through a secure channel.