Anti-Money Laundering (AML) Policy

The purpose of this policy is to prevent Blessa from being used to facilitate money laundering, terrorist financing, or other illegal activities. This policy establishes the framework for compliance with applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations.

Scope

This policy applies to:

• All employees, contractors, and agents of Blessa.
• All creators, donors, and any other users utilizing Blessa.

Definitions

• Money Laundering: The process of concealing the origins of illegally obtained money by passing it through legitimate channels.
• Terrorist Financing: Providing funds for terrorist activities.
• Politically Exposed Person (PEP): An individual in a prominent public position, posing higher corruption risk.
• Sanctioned Persons or Entities: Individuals or organizations on sanctions lists maintained by authorities such as OFAC, EU, or UN.

Risk-Based Approach

Blessa adopts a risk-based approach to identify, assess, and mitigate AML risks. This approach includes:

• Periodic risk assessments of the platform’s operations and users.
• Allocation of resources proportional to the level of identified risks.

Key AML Measures

Customer Due Diligence (CDD)

• Creators:
  • Identity Verification: Identity checks for creators will be conducted through an FCA-regulated payment processor, ensuring compliance with applicable laws and regulations.
  • Business Purpose: Obtain information about the creator’s content and intended use of the platform.
  • Ongoing Monitoring: Regularly review creator accounts for unusual activity or violations of platform policies.

Enhanced Due Diligence (EDD)

EDD is applied in higher-risk situations, such as:

• Creators from high-risk jurisdictions.
• Transactions exceeding pre-set thresholds.
• Users flagged as PEPs or listed on sanctions databases.

Transaction Monitoring

Automated monitoring of transactions to detect:

• High-frequency or high-value donations.
• Structuring (multiple small donations below thresholds).
• Donations from high-risk geographies.

Suspicious transactions are flagged for review and escalated to the AML officer.

Sanctions Screening

All users and transactions are screened against international and national sanctions lists. Accounts matching sanctions lists are frozen, and relevant authorities are notified.

Record Keeping

Blessa will retain all relevant records for a minimum of [5–7 years] to comply with applicable regulations. Records include:

• User KYC documentation for creators.
• Transaction logs.
• Reports of suspicious activity.

Reporting Suspicious Activities

Internal Reporting

Employees must report any suspicious activity to the designated AML officer. Creators are monitored for behavior indicating possible money laundering or fraud.

External Reporting

Suspicious Activity Reports (SARs) are filed with relevant authorities, such as the Financial Intelligence Unit (FIU), within required timeframes.

Employee Training

All employees handling user accounts, payments, or transactions receive regular training on:

• AML laws and regulations.
• Recognizing suspicious activity.
• Procedures for reporting suspicious activity.

Internal Controls

• Appoint a designated AML officer responsible for implementing and maintaining this policy.
• Conduct regular audits of AML compliance programs.
• Update the AML policy periodically to reflect regulatory changes or emerging risks.

Payout Controls

• Verify payout accounts (e.g., bank accounts or e-wallets) to ensure ownership by the creator.
• Implement payout limits for new creators or accounts flagged as higher-risk.
• Monitor payouts for unusual patterns, such as rapid withdrawal of donated funds.

Prohibited Activities

The platform strictly prohibits:

• Use of Blessa for illegal activities, including but not limited to:
  • Laundering proceeds of crime.
  • Funding terrorism.
  • Facilitating fraud or scams.
• Engagement with users flagged as sanctioned or engaged in illegal behavior.

Review and Updates

This AML policy is reviewed at least annually or when significant regulatory or operational changes occur. Updates are approved by Blessa’s senior management.

Consequences of Non-Compliance

Failure to comply with this AML policy may result in:

• Termination of user accounts.
• Reporting to law enforcement or regulatory bodies.
• Disciplinary action for employees, up to and including termination.

Approval and Oversight

This policy is approved by Blessa’s senior management and is overseen by the AML Officer, Jojo Masala, who ensures its effective implementation.