MemberDrive Know Your Customer and Anti-Money Laundering Policy (hereinafter - the “KYC/AML Policy”) is designated to prevent and mitigate possible risks of MemberDrive being involved in any kind of illegal activity.
Both international and United States regulations require MemberDrive to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its users.
KYC/AML Policy covers the following matters:
- Verification procedures.
- Compliance Officer.
- Monitoring Transactions.
- Risk Assessment.
- Sanctions Concerns.
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, MemberDrive establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
1.1 Identity verification
1.2 Card Verification
MemberDrive uses Stripe's Radar fraud protection service. Users who provide payment information in connection with MemberDrive's Services must pass card verification in accordance with Stripe's Radar policies.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by MemberDrive, whose duty is to ensure the effective implementation and enforcement of the KYC/AML Policy. It is the Compliance Officer’s responsibility to supervise all aspects of MemberDrive’s anti-money laundering and counter-terrorist financing, including but not limited to:
- Collecting Users’ identification information.
- Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.
- Monitoring transactions and investigating any significant deviations from normal activity.
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.
- Updating risk assessment regularly.
- Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
3. Monitoring Transactions
Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, MemberDrive relies on various data analysis as a risk-assessment and suspicion detection tools. MemberDrive performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
- Checking users against recognized “black lists”,
- Placing users on watch and service denial lists,
- Opening cases for investigation where needed, and sending internal communications and filling out statutory reports, if applicable,
- Ensuring that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer,
- Requesting the user to provide any additional information and documents in case of suspicious transactions,
- Suspending or terminating a user's campaign(s) or membership(s) when MemberDrive has firm suspicion that such user engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
4. Risk Assessment
MemberDrive, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, MemberDrive is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
5. Sanctions Concerns
As a U.S. company, MemberDrive complies with all sanctions programs administered by the U.S. Office of Foreign Assets Control (OFAC). This includes both prohibitions against interactions with certain individuals and entities as well as comprehensive bans on business dealings involving certain countries or regions that are targeted by sanctions regimes.
MemberDrive screens all accounts, including Campaign accounts, in compliance with our own obligations under these sanctions regimes. If an account is flagged as a possible sanctions concern, MemberDrive will pause campaigns and/or memberships belonging to the user and reach out to the account holder via email to request additional information. Campaigns and/or memberships for the account will remain paused until the review has been cleared.
Updated March 11, 2020.