Last updated November 11, 2021
SCOPE AND APPLICABILITY
WHAT CONSTITUTES MONEY LAUNDERING AND SUSPICIOUS TRANSACTIONS
(i) Users that are reluctant to provide complete information, or those that provide incomplete, false or suspicious information and/ or are unwilling to comply with ZedAid’s identification requirements;
(ii) Users that appear as agents or representatives for other individuals or organisations, but refuse to provide complete information about such individuals or organisations;
(iii) Any person, including a ZedAid support staff, that is concerned about or seeks to avoid any reporting requirements or refuses to maintain required records;
(iv) Being a digital platform, Payments made in cash or cash equivalents are not applicable;
(v) Donations of large amounts that appear to be out of place or inconsistent with normal donation patterns, in the absence of any legitimate requirement for such donation;
(vi) Requests for payments to be made in unrelated countries or to third parties;
(vii) Multiple partial payments from various parties on behalf of a single user and/or multiple partial payments from various locations;
(viii) Users making payments in one form, then requesting refunds in other forms (for example, making payments by credit card, but requesting refunds in cash or by wire transfers);
(ix) Users making contributions, followed by immediate requests to wire out or transfer the funds to a third party or firm, without connected purposes;
(x) Users requesting for donations to be paid in cash or wired to a third party or firm, without connected purposes;
(xi) On-boarding of users by ZedAid employees based on incomplete information or in contravention of ZedAid’s policies;
(xii) Acceptance of incentives by a ZedAid employee for breaching ZedAid’s policies;
STEPS TO ENSURE COMPLIANCE
ACTION BY ZedAid
Upon receiving knowledge of suspicious transactions or any breach of applicable law or this policy, ZedAid may take one or more of the following steps:
CONSEQUENCES OF AML POLICY VIOLATIONS
Users agree that irreparable damage would occur to ZedAid if any of the provisions of this AML Policy are not complied with. Accordingly, users agree that ZedAid is entitled to claim damages from users for violating this AML Policy in addition to any other remedy to which they are entitled at law or in equity.
To the extent permitted under applicable law, ZedAid shall have no liability in respect of any illegal transactions that take place on its platform. ZedAid shall also not be liable for any consequences (monetary or otherwise) suffered by the stakeholders of a campaign or other users if it takes action (in its sole discretion) pursuant to this policy and applicable law.
COMPLIANCE AND CO-OPERATION
This policy must be complied with by the user in addition to the local laws applicable to the users in their home jurisdictions. Users agree that upon being requested by ZedAid or its legal counsel or any government authorities they shall fully cooperate with them in any formal or informal inquiry, investigation or other proceedings. In this regard, users agree that they will promptly provide all information or documents they may possess relevant to the inquiry, investigation or legal action or proceeding without any demur and at their own costs.
MAINTENANCE AND DISCLOSURE OF RECORDS
To help us comply with applicable law we obtain and record information that identifies users on our platform. This means we must ask you for certain identifying information, including copies of government-issued ID and such other information or documents that we consider appropriate to verify your identity. ZedAid hereby reserves the right to maintain records confirming the identity of its users and the transactions undertaken by them for as long as may be required under applicable law. ZedAid also reserves the right to disclose this information to government authorities in case of any inquiry, investigation or other proceedings initiated by them.
No policy, law or code of conduct can foresee every situation, and ZedAid relies on the good faith of its users to promptly report any concerns or ‘red flags’ envisaged by this AML Policy to firstname.lastname@example.org or to government authorities.
ZedAid reserves the right to modify and amend this AML Policy at any time. ZedAid will not be liable to any users or third parties for any modification or amendment. Users are recommended to review the AML Policy from time to time, for the most up-to-date version. In the event of modification or amendment to the AML Policy, continued use of the ZedAid platform, after notice of material changes, will constitute acceptance of the modified or amended terms. If the modifications or amendments to the AML Policy are not acceptable by any registered users, the only remedy would be to cease usage of the ZedAid platform, by deleting the relevant account or writing to us at email@example.com.
Any dispute or claim relating in any way to this AML Policy is subject to the exclusive jurisdiction of the courts in Mumbai. Laws prevailing in India, without regard to principles of conflict of laws, will govern this AML Policy and any dispute related to/arising from this AML Policy, between ZedAid and the concerned user.
This AML Policy will survive the termination of ZedAid’s relationship with the concerned user.
Should have any queries or require any assistance in relation to this policy, please write to us at firstname.lastname@example.org.