Anti-Money Laundering & Counter-Terrorist Financing Policy

1.1 ChaiLink is committed to preventing use of the Platform for money laundering (ML), terrorist financing (TF), proliferation financing, or sanctions evasion.

1.2 The Board of Directors (or designated compliance committee) approves this Policy annually.

1.3 A designated Compliance Officer (MLRO) reports to senior management with independent authority to escalate STR filings.

1.4 All staff receive annual AML/CFT training with enhanced modules for payment operations.

2.1 Annual ML/TF risk assessments cover products (voluntary contributions), customer types (Creators, anonymous Supporters), delivery channels (mobile web), and geographic exposure (primarily Pakistan).

2.2 Higher-risk indicators: rapid high-volume inflows, structuring, payout destination mismatch, high-risk jurisdictions, PayFast-prohibited business categories.

2.3 Outcomes drive KYC tiers, transaction monitoring rules, and EDD triggers.

3.1 Simplified Due Diligence for low-value, occasional Supporter Contributions without account registration.

3.2 Standard CDD for Creators: verified identity, address, occupation, payout account in own name.

3.3 Enhanced Due Diligence for PEPs, high-net-worth Creators, adverse media, or unusual patterns.

3.4 Ongoing due diligence with KYC refresh every twelve (12) months or upon trigger events.

4.1 Automated rules monitor velocity, amount anomalies, geographic inconsistencies, device fingerprint reuse, and structuring.

4.2 Manual review queue for high-risk alerts; disposition within forty-eight (48) hours.

4.3 Integration with PayFast Guardian, partner fraud networks, and FMU typologies.

5.1 STRs filed with FMU via GoAML without tipping off the subject.

5.2 Timeline: as soon as practicable, no later than three (3) business days from suspicion crystallization.

5.3 Accounts may be frozen pending investigation per AMLA Section 11 and SBP directives.

6.1 Screening against UN Consolidated List, applicable OFAC obligations, and NACTA proscribed persons lists.

6.2 Real-time screening at onboarding and monthly batch rescreening.

6.3 Matches result in rejection, suspension, and potential STR filing.

7.1 CDD records, transaction logs, STR documentation retained minimum seven (7) years per AMLA Section 7.

7.2 Minimum two (2) years online transaction records per PayFast merchant obligations.

7.3 Records available for SBP, FMU, PayFast/APPS, and law enforcement upon lawful request.

8.1 Money laundering, terrorist financing, sanctions evasion, or processing for sanctioned entities.

8.2 PayFast-prohibited categories: firearms, alcohol, explosives, pornography, live animals, illegal drugs, fireworks, hazardous materials, gambling, MLM/matrix schemes, bulk email lists, work-at-home schemes, wire-transfer products, cryptocurrency, and any unlawful products or services under Pakistani law.

8.3 Mule accounts, third-party payouts, or falsified supporter transactions constitute fraud and will be reported.

9.1 Employee AML/CFT induction within thirty (30) days of hire and annual refresher training.

9.2 Creator educational materials on lawful use and tax obligations via dashboard.

9.3 Whistleblower channel: compliance@chailink.co.

10.1 User-level: suspension, fund holds, permanent ban, law enforcement referral.

10.2 Institutional: AMLA penalties for willful negligence; ChaiLink maintains controls to prevent liability.

10.3 Cooperation with FIA, FMU, SBP, and PayFast enforcement actions.