AML/CTF Compliance Policy

1. Purpose

This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Compliance Policy outlines the measures taken by With A Bow, a trading name of L.J Gulvin & N.A James-New (ABN 95 736 570 889) ("we", "us", "our") to detect, prevent, and report suspected money laundering and terrorism financing activities through the With A Bow platform.

2. Regulatory framework

While With A Bow is not a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), we voluntarily adopt AML/CTF best practices as part of our commitment to operating responsibly. We rely on our payment processor, Stripe, which is a regulated entity under AUSTRAC, for primary AML/CTF obligations including customer identification.

3. Risk-based approach

We apply a risk-based approach to monitoring transactions on our platform:

• Low risk: Standard gift contributions within normal thresholds
• Medium risk: Contributions flagged by automated monitoring (e.g. high-value single contributions, rapid succession of payments)
• High risk: Patterns consistent with structuring, unusually high aggregated amounts, or known adverse indicators

4. Automated monitoring

Our platform implements automated monitoring systems that flag potentially suspicious activity, including:

• Single contributions exceeding $10,000 AUD
• Aggregated contributions to a single event exceeding $25,000 AUD within 30 days
• Multiple rapid contributions from the same source
• Unusual patterns inconsistent with expected gift-giving behaviour

Flagged transactions are reviewed by our team before payouts are released.

5. Know Your Customer (KYC)

Event Owners requesting payouts may be subject to identity verification. We collect and verify:

• Full legal name
• Email address
• Australian bank account details (BSB, account number, account name)

Enhanced due diligence may be required for higher-risk transactions, including additional identification documents.

6. Payout controls

• Payouts may be placed on hold where AML flags have been raised, pending review and resolution.
• We reserve the right to refuse or delay any payout where we have reasonable grounds to suspect it may involve proceeds of crime or terrorism financing.
• Chargebacks or disputes will automatically trigger a payout hold on the affected event.

7. Record keeping

In accordance with Australian financial recordkeeping obligations, we retain all financial records - including contributions, payouts, fee logs, AML flags, and disputes - for a minimum of 7 years.

8. Reporting

Where we identify activity that we reasonably suspect may involve money laundering or terrorism financing, we will:

• Withhold the relevant payout
• Report the matter to AUSTRAC if required
• Cooperate with law enforcement agencies as necessary

9. Staff awareness

All personnel with access to financial data or payout processing are made aware of AML/CTF risks and the procedures outlined in this policy.

10. Policy review

This policy is reviewed annually or whenever there are material changes to our services, regulatory requirements, or risk environment.

11. Contact us

For compliance enquiries, contact us at compliance@withabow.com.au.