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:
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.
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.
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:
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
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:
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.
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.
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.