1. Scope and Applicability

ShareYourFortune ensures that it is committed to maintain ethical charity practices, which conforms to the applicable law and its crowd funding is not used for funding illegal activities. To accomplish this we have prepared this Anti-Money Laundering Policy (“AML Policy”) and request you to carefully read and follow the policy. This policy is in addition to your obligations under applicable laws on the prevention of money laundering and does not detract in any manner from those obligations. We urge you to be aware of your obligations under these applicable law and ShareYourFortune could only comply with its obligation under these laws only if you co-operate as well. Thus we seek the same through this policy.

To ensure that ShareYourFortune is not involved in any transactions that are suspect or know to be the means of laundering money. Users of ShareYourFortune are urged to promptly contact government authorities to facilitate any action that may be appropriate if any such suspicious activity is noted.

This money laundering policy applies to all persons using and accessing ShareYourFortune’s platform. This includes all donors, contributors, cause providers, and persons visiting our platform. All these persons are collectively referred to as “Users” or “users”.

2. What Constitutes Money Laundering and Suspicious Transactions

Money Laundering can be understood as an act or attempt (directly or indirectly and even by association in one step of a series of transactions) to conceal or disguise the origin and ownership of proceeds obtained illegally, in a way that it appears to have originated from legitimate sources; thus avoiding prosecution, conviction and confiscation of such proceeds. Terrorist organisations, tax evaders, smugglers, persons involved in bribery or any persons that receive money for illegal activities and/or through illegal means may launder money.

In order to recognize transactions involving money laundering requires much awareness of possible suspicious activity, which may arise at any time. Below is an indicative list of actions that persons associated with ShareYourFortune should be careful of. This list is not comprehensive as all the situation cannot be predictable. Hence, please be aware of these situations that may be indications of money laundering activity which can appear individually or together:

• 2.1Users those who are not willing to provide complete information, or those who provide incomplete, false, suspicious information and are reluctant to comply with ShareYourFortune’s identification requirements;
• 2.2Users who are appeared as an agent for other individuals, or organizations but refuse to provide complete information about such individuals or organizations;
• 2.3Any person, including an employee of ShareYourFortune who is concerned or seek to avoid any reporting requirements, or refused to maintain any required records;
• 2.4Payments made in cash or cash equivalents only (such as money orders, traveller’s cheques, internet currencies or prepaid cash cards);
• 2.5Donations 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;
• 2.6Requesting payment to be made in unrelated countries or to third parties;
• 2.7Multiple partial payments from various parties on behalf of a single user and/or multiple partial payments from various locations;
• 2.8Users making payments in one form , then requesting payments even in different forms(for example, making payments by credit card, but requesting refunds in cash or by wire transfers);
• 2.9Users making contributions, followed by immediate requests to wire out or transfer the funds to a third party or firm, without connected purposes;
• 2.10Users requesting for donations to be paid in cash or wired to a third party or firm, without connected purposes;
• 2.11On-boarding of users by ShareYourFortune employees based on incomplete information or in contravention of ShareYourFortune’s policies;
• 2.12Acceptance of incentives by a ShareYourFortune employee for breaching ShareYourFortune’s policies;
• 2.13Users connected to countries and/ or persons identified as non- cooperative by the Reserve Bank of India, Financial Action Task Force on Money Laundering established by the G-7 Summit in 1987, Office of Foreign Assets Control, US Department of Treasury and international organisations against money laundering.

3. Steps to Ensure Compliance

• 3.1Compliance with applicable law: Users must at all times, make sure that they access, and /or utilize ShareYourFortune’s platform in compliance with all the applicable law. Users who are donating or contributing to any cause need to ensure that the fund that they have used to donate was not originated from any unlawful activity. Likewise, users collecting funds for a campaign must ensure that they are not using it for any illegal purpose.
• 3.2Reporting Suspicious Activity: Users must, and without delay, report to relevant government authorities any suspicious activity or red flag that they might come across while accessing or using ShareYourFortune’s platform.

4. Action by ShareYourFortune

Upon receiving knowledge of suspicious transactions or any breach of applicable law or this policy, ShareYourFortune may take one or more of the following steps:

• 4.1Probe into the incident;
• 4.2Report the incident directly to the appropriate government authority;
• 4.3Suspend or delete a campaign;
• 4.4Suspend or delete the user account(s);
• 4.5Other steps/actions that ShareYourFortune may deem appropriate.

5. Consequence of AML Policy Violation

Users are here by approve that irreversible damage would occur to ShareYourFortune if any of the provisions of this AML Policy are not complied with. Accordingly, users agree that ShareYourFortune 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.

6. No Liability

To the extent permitted under applicable law, ShareYourFortune shall have no liability in respect of any illegal transactions that take place on its platform. ShareYourFortune shall also not be liable for any consequences (monetary or otherwise) suffered by the stakeholders of a cause or other users if it takes action (in its sole discretion) pursuant to this policy and applicable law.

7. 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 ShareYourFortune 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.

8. 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. ShareYourFortune 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. ShareYourFortune also reserves the right to disclose this information to government authorities in case of any inquiry, investigation or other proceedings initiated by them.

9. Good Faith

Not every situation can be predicted by any policy, law, code of conduct. ShareYourFortune relies on the good faith of its users to promptly report any concerns or ‘red flags’ envisaged by this AML Policy to government authorities. ShareYourFortune presumes that all information (including documents relating to the identity of its users) is true and accurate and the users represent the same to ShareYourFortune by virtue of using the services of ShareYourFortune.

10. Amendment

ShareYourFortune reserves the right make amendments and modification to this policy time to time. ShareYourFortune will not be liable to any users or third parties for any modification or amendment. We urge the users to review the AML policy frequently, for the most updated version. The continued use of ShareYourFortune platform after the notice of material changes, tells the acceptance by the users of the modification 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 ShareYourFortune platform, by deleting the relevant account.

11. Governing Law

Any dispute or claim relating in any way to this AML Policy is subject to the exclusive jurisdiction of the courts in Kerala. 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 ShareYourFortune and the concerned user.

12. Survival

This AML Policy will survive the termination of ShareYourFortune’s relationship with the concerned user.

13. Queries

If you have any queries or require any assistance in relation to this policy, please write to us at support@shareyourfortune.org