Anti-fraud and money laundering
Our procedures to combat money laundering, fraud and terrorist financing are in accordance with international FATF standards
Anti-money laundering, fraud and terrorist financing policy
Company establishment date: June 29, 2026 | Version: 2.0 FOR RELIEF LTD is committed to the highest standards of financial integrity and combating financial crime. This policy sets out the comprehensive framework for preventing money laundering (AML), countering the financing of terrorism (CFT), fraud detection and reporting. International frameworks to which this policy complies: • The 40 international recommendations of the Financial Action Task Force (FATF). • Fifth European Anti-Money Laundering Directive (5AMLD — 2018/843/EU) • Sixth European Anti-Money Laundering Directive (6AMLD — 2018/1673/EU) • British Anti-Money Laundering Act (POCA 2002 and Money Laundering Regulations 2017) • Turkish Anti-Money Laundering Law No. 5549/2006 • Arab Regulations for Combating Money Laundering (MENAFATF) • Wolfsberg Principles for humanitarian relief organisations
Definition of money laundering and terrorist financing
Money Laundering: The process of legitimizing money earned from illegal activities by introducing it into the formal financial system. It usually goes through three stages: 1. Placement stage: introducing illicit funds into the financial system. 2. Layering: Conducting multiple transactions to hide the true origin of the funds. 3. Integration stage: returning funds to the formal economy in the form of legitimate funds. Terrorist Financing: Providing or collecting funds - whether legitimate or illegitimate - with the intention of using them to finance terrorist activities or terrorist organizations. Why does this matter to the donation sector? The non-profit sector is at risk of being exploited for money laundering or terrorist financing due to: • The large volume of transactions and their geographical spread • Charitable character that may be exploited to lend legitimacy • Difficulty verifying the identity of donors in some cases
Know Your Customer (KYC) procedures
We implement the “Know Your Customer — KYC” policy according to the risk levels: Level 1 — Basic Verification (for regular donations): • Payment data validation (via Stripe/PayPal). • Verify that the donor’s name is not on international sanctions lists. • Monitor transaction patterns to detect anomalies. Level 2 — Medium Verification (for large donations): Applies to donations above a certain threshold (determined internally): • Require full name and verifiable email. • Review the history of the donor’s transactions with the platform. • Verify the source of funds if necessary. Level 3 - Enhanced Due Diligence - EDD: Applied in high-risk cases: • Very large donations from unknown people. • Donations from countries on the FATF high-risk lists. • Unexplained donation patterns (such as repeated donations in amounts below the mandatory reporting threshold). • Donors from the category of “Politically Exposed Persons” (PEPs - Politically Exposed Persons). In these cases we may ask: • A copy of an official identity document. • A statement of the source of funds. • Clarifying the purpose of the donation. • Stop the transaction pending verification.
Transaction monitoring procedures
We adopt a multi-layered monitoring system to detect suspicious transactions: 1. Real-time Screening: Every transaction goes instantly through: • Check the US OFAC sanctions list • Examination of European sanctions lists (EU Consolidated List) • Examination of the United Nations Sanctions List. • Examination of the UK Sanctions List. • Examination of applicable regional terrorism lists 2. Red Flags we monitor: • Donate small amounts repeatedly at very short intervals (Smurfing) • Using credit cards with different names or addresses for the same user • Request a refund of part of the donation through a different payment method • Donations of IP addresses in countries subject to comprehensive international sanctions • Payment modes that test the limits of the card processing system (Card Testing). • Donations accompanied by a request to influence the direction of funds to a specific party 3. Periodic manual review: • Weekly review of unusual transactions by the financial officer • Monthly audit of donation patterns to detect long-term anomalies • Quarterly assessment of AML risks and updating detection mechanisms
Rejecting transactions and freezing funds
When do we decline the transaction? We will reject any transaction immediately and without prior notice if: • The donor’s name matches an approved international sanctions list. • A stolen or reported fraudulent credit card was used. • The transaction was from an IP in a country with a comprehensive ban that prevents transactions. • The payment gateway (Stripe/PayPal) rejected the transaction for security reasons. • The donor was found to be using a fake identity or hacked data. • There have been strong indicators indicating intent to launder money. What happens after rejection? • The donor is notified in a general message (without revealing the reason for the security rejection). • Records of declined transactions are kept for 5 years. • The competent authorities will be notified if the matter exceeds the limits of reasonable suspicion. Freezing funds: In cases that require investigation: • Funds are temporarily frozen until the verification process is completed. • Priority is given to cases involving high risks. • The funds will be recovered if their legality is proven, or they will be referred to the competent authorities if the opposite is proven.
Suspicious Transaction Reporting (STR)
Our reporting obligations: We are committed to submitting suspicious transaction reports (STR) to the competent authorities in accordance with applicable laws: • In the European Union: for local Financial Intelligence Units (FIUs). • In the United Kingdom: to the National Crime Agency (NCA) via the UKFIU system • In Türkiye: Finance Unit (MASAK) • In Arab countries: to the relevant regulatory authorities (such as the Financial Information Processing Unit in the Emirates) What prevents us from disclosing: According to the law, we are prohibited from informing suspects that their transactions are under investigation or that they have been reported (Tipping Off). This ban is mandatory and protects us legally. Records and documentation: We keep all records related to precautionary measures and suspicious reports for a period of at least 5 years in accordance with FATF requirements.
Responsibility for compliance and training program
Compliance Officer (MLRO): The organization appoints a Compliance Officer (Money Laundering Reporting Officer — MLRO) responsible for: • Supervising the implementation of the AML/CFT policy • Regularly review and update compliance procedures • Receiving internal reports of suspicious transactions • Preparing STR reports and sending them to the competent authorities • Communicating with regulatory and supervisory authorities Staff training: • All employees receive mandatory AML/CFT training upon hire • Annual update training on the latest money laundering methods and identifying them • Periodic tests to ensure understanding of procedures • A documented training record for each employee Risk assessment: We conduct a comprehensive risk assessment at least once a year, or when significant changes occur in the organization's operations, and update our procedures based on the assessment results.
Report fraud
If you discover or suspect any fraudulent activity: Email: info@forrelief.org We respond within: 24 hours on business days What is considered fraud that we require you to report? • Using the organization’s name or logo to collect unauthorized donations • Claims to be associated with the organization for incorrect purposes • Using other donors’ data to make fake donations • Any activity that suggests the organization is being exploited for illegal purposes We guarantee: • Deal with all reports confidentially • Whistleblower Protection in accordance with applicable laws • Investigate every report seriously and objectively • Cooperate fully with law enforcement when appropriate
To report suspicious activity
Contact our compliance team immediately — we respond within 24 hours