GGenerosity.co.nz

AML/CFT Policy

Generosity.co.nz

Version: 3.0 · Effective date: 25 August 2026

3.0 changes: clarified that the Platform is not a financial service provider and does not operate a wallet or stored value facility, that its obligations relate only to its own fee revenue and operations, and that it relies on Stripe's regulated KYC and AML controls; added additional risk indicators, document-request powers, permanent bans, sanctions restrictions, and staff obligations.

Generosity.co.nz does not receive, hold or route donations, sale proceeds or commissions. All payments occur directly between buyers, fundraisers and wholesalers through Stripe. We do not operate a wallet, stored value facility, or pooled funds.

The Platform relies on Stripe Connect for seller KYC; confirm obligations with a NZ lawyer.

1. Purpose

This policy sets out how Generosity.co.nz manages the risk of its services being used for money laundering or financing terrorism, and how it complies with applicable New Zealand law (including the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 where it applies to us).

Generosity.co.nz is not a financial service provider and does not provide regulated financial products or services. Our AML/CFT obligations, where they apply, relate only to our own fee revenue and platform operations.

2. Our approach

  • KYC for sellers and fundraisers: all fundraisers and sellers complete Stripe Connect onboarding, which includes identity verification, bank account validation and risk scoring. Charity fundraisers provide their Charities Services registration number.
  • Reliance on Stripe: Stripe performs identity verification, bank account validation, sanctions screening and fraud monitoring for all sellers and fundraisers as a regulated payment provider.
  • No cash, no client money: all funds flow electronically and directly between the buyer and the seller through their own Stripe accounts. The Platform does not receive, hold or route donations, sale proceeds or commissions — it only receives payment for its own platform fee. The Platform never handles cash.
  • Verification documents: we may require proof of identity, proof of address, proof of authority to run a campaign, or proof of ownership or authenticity of goods. Failure to provide requested documents may result in suspension.
  • Audit trail: donations, orders, payouts, refunds, disputes and moderation decisions are logged and retained.
  • Monitoring: automated risk scoring and manual review identify unusual activity (see the fraud systems section of the architecture docs).

3. Risk indicators we watch for

  • Campaigns or listings inconsistent with the stated cause;
  • Rapid or unusual donation patterns;
  • Unusual refund patterns;
  • Many transactions just below thresholds;
  • High-risk goods (restricted items, counterfeit risk);
  • Fundraisers or sellers rapidly changing bank accounts;
  • Multiple campaigns linked to the same identity;
  • Fundraisers trying to avoid verification or bypassing Stripe verification;
  • Use of VPNs or anonymising tools;
  • Payout requests to accounts inconsistent with the connected account;
  • Duplicate or copycat campaigns;
  • Fundraisers or sellers in high-risk industries (crypto, gambling, adult content);
  • Prohibited items or gambling without a licence;
  • Sanctioned parties or high-risk jurisdictions.

4. What we do

  • Review: flagged activity is reviewed by staff.
  • Hold: payouts or commission invoicing may be paused while we investigate.
  • Request: we may request identity documents, proof of address, proof of ownership, or proof of authority to run a campaign.
  • Report: where we are required to report suspicious activity, we will do so to the appropriate authority (e.g. the NZ Police FIU) without tipping off the customer.
  • Refuse: we may refuse, suspend or close accounts, reject transactions, and permanently ban users for serious AML/CFT breaches.
  • Record: we keep records of verification, transactions and decisions for the periods required by law.

5. Sanctions screening

We use available screening tools (including through Stripe) to help ensure we don't deal with sanctioned parties or jurisdictions. We do not allow fundraisers or sellers in sanctioned jurisdictions, and we may require additional verification for users in higher-risk regions.

6. Donor anonymity

Anonymous donations are permitted for campaigns configured to allow them, but all transactions still pass through Stripe's identity and fraud controls, and anonymous donations generate the same Stripe fraud and risk metadata as any other payment. Donors can't be fully anonymous to the payment system.

7. Staff obligations

Staff must follow this policy, protect customer information, and report suspected suspicious activity to the compliance contact without delay. Staff must avoid tipping off users during investigations and must complete AML/CFT training annually.

8. Training and review

We review this policy annually and whenever there are significant changes to the business, law, or risk environment. We maintain internal documentation of our AML/CFT procedures and risk assessments.

9. Contact

compliance@generosity.co.nz