Join Creators

COMPLIANCE & AML POLICY

Effective date: 28.05.2026

1. Introduction and Purpose

This Compliance & AML Policy ("Policy") forms an integral part of the Terms of Use of the DonateOpen platform (donateopen.com, "Platform") and applies to all Users. The Platform is operated by DonateOpen Co. (hereinafter — "DonateOpen," "we"). The purpose of this Policy is to prevent the use of the Platform for money laundering, terrorist financing, fraud, sanctions evasion, and other unlawful activities, as well as to ensure the integrity and security of the Platform. This Policy should be read in conjunction with the Terms of Use, the User Content & DMCA Policy, and the Privacy Policy.

2. Terms and Definitions

This Policy uses the terms defined in the Terms of Use, including:

  • Platform — DonateOpen.com website owned, operated and represented by DonateOpen Co.
  • User — any person interacting with the Platform.
  • Creator — a User who creates various content and a creator page on DonateOpen.
  • Donator — a User who sends a donation to a Creator.
  • Guest — a User who makes a donation without creating an account on the Platform.
  • Platform Visitor (Visitor) — a User who browses the Platform without logging in or making donations.
  • KYC (Know Your Customer) — client identification and verification procedures.
  • AML/CFT — anti-money laundering and counter-terrorist financing.
  • Suspicious activity — actions that may indicate fraud, money laundering, terrorist financing, sanctions evasion, or any other violation of this Policy or applicable law.

3. Nature of the Platform and Allocation of Roles

3.1. DonateOpen is an information technology service and does not hold, accumulate, transfer, or manage User funds, and is not a payment system, payment agent, bank, or other financial institution (see Terms of Use). Accordingly, DonateOpen does not perform the functions of a regulated financial intermediary.

3.2. All payments and transfers are made directly between the Donator and the Creator through the third-party licensed payment provider Stripe.

4. Financial Compliance on the Stripe Side (KYC/AML)

4.1. Know Your Customer (KYC) procedures, as well as anti-money laundering and counter-terrorist financing (AML/CFT) checks with respect to payments, are carried out by Stripe as a regulated payment provider.

4.2. Stripe conducts full KYC verification of Creators before they are permitted to receive payouts on the Platform. Without successfully completing verification and connecting a Stripe Connected Account, a Creator cannot receive donations.

4.3. Stripe performs identity verification, sanctions list screening, transaction monitoring, and other financial compliance measures in accordance with applicable law and its own policies. Use of the Platform constitutes the Creator's agreement to Stripe's terms and verification procedures.

4.4. Responsibility for the KYC verification of Creators, for payouts, and for anti-fraud procedures with respect to payments lies with Stripe as the regulated payment provider. DonateOpen does not perform the aforementioned functions, does not control or guarantee the outcomes of verifications, decisions regarding payouts, suspensions or blocks, or any other actions of Stripe, and bears no liability for them.

4.5. Screening for politically exposed persons (PEPs) and their close associates forms part of the KYC/AML compliance framework applied to Creators prior to and during their use of the Platform. As with other KYC/AML procedures, PEP screening is carried out by Stripe as the regulated payment provider in accordance with its own policies and applicable law. DonateOpen does not independently perform PEP screening and bears no liability for Stripe's screening decisions or outcomes.

5. Platform-Level Compliance

5.1. At its own level, DonateOpen applies reasonable technical and organizational measures to ensure account integrity, prevent fraud and abuse, and monitor compliance with the prohibitions set out in this Policy.

5.2. DonateOpen does not disclose the specific algorithms, thresholds, or methods used to detect violations, as their disclosure would reduce their effectiveness. DonateOpen reserves the right to modify and improve such measures at its sole discretion.

6. Sanctions and Territorial Restrictions

6.1. The Platform is not intended for individuals and organizations included in sanctions lists (including those of OFAC USA, the EU, the UN, and the United Kingdom), nor for persons located in jurisdictions subject to comprehensive sanctions.

6.2. By using the Platform, the User represents and warrants that they are not a sanctioned person and are not acting on behalf of such a person. DonateOpen reserves the right to restrict access to the Platform on a territorial basis.

7. Prohibited Activities

Users are strictly prohibited from using the Platform for the following purposes and actions:

  • Money laundering. Giving a lawful appearance to the possession, use, or disposal of funds obtained through criminal activity; concealing the origin of funds.
  • Terrorist financing and financing of unlawful activities. Collecting or transferring funds to finance terrorism, violent extremism, or other unlawful activities.
  • Use of another person's account. Using another person's account, granting third parties access to one's own account, or gaining unauthorized access to another person's account.
  • False information and impersonation. Providing inaccurate registration data, using another person's personal or payment details, or impersonating another individual or organization.
  • Multiple accounts and circumvention of blocks. Creating multiple accounts for the purpose of abuse, or circumventing a previously imposed block.
  • Fraud. Any form of fraud, including the use of stolen or third-party payment instruments, bad-faith refunds and chargeback fraud, and phishing.
  • Structuring of transactions. Splitting transactions for the purpose of circumventing monitoring thresholds and verification procedures.
  • Corruption and bribery. Using the Platform to give or receive bribes or engage in commercial bribery.
  • Facilitation of tax evasion. Using the Platform to conceal income or evade the payment of taxes.
  • Financing of prohibited goods and services. Collecting funds in connection with goods and services prohibited by the User Content & DMCA Policy or by law.
  • Circumvention of security controls. Any attempts to bypass the Platform's security measures and controls.

8. Identification and Verification at the Platform Level

DonateOpen uses passwordless authentication (login via a one-time code sent to email or via Google Sign-In) and employs technical signals (including a device identifier) to prevent fraud (see the Privacy Policy and the Cookie Policy). DonateOpen reserves the right to request additional information or confirmations from the User and to restrict account features pending the completion of a review.

9. Monitoring and Fraud Prevention

DonateOpen conducts reasonable monitoring of activity on the Platform for the purpose of detecting fraud and abuse, and reserves the right to initiate a review where suspicion arises. Specific monitoring methods and parameters are not disclosed (see Section 5).

10. Platform Rights and Response Measures

10.1. DonateOpen reserves the right, unilaterally, at any time, for any reasonable cause, and without prior notice, to suspend or block any account, remove content, and restrict access to Platform features (see Terms of Use).

10.2. DonateOpen reserves the right to request from the User information and documents necessary to verify compliance with this Policy.

10.3. DonateOpen does not hold or control User funds and cannot "freeze" funds within the Stripe system. Matters relating to funds, payouts, and blocks on the Stripe side are governed by Stripe's policies and are resolved by the User directly with Stripe (see Terms of Use).

10.4. DonateOpen reserves the right to report violations and suspicious activity to Stripe, competent governmental and law enforcement authorities, to disclose information in cases provided for by law (see Privacy Policy), and to cooperate with ongoing investigations.

10.5. DonateOpen implements the measures set out in this Policy at its sole discretion, does not guarantee the detection or prevention of all violations, and, to the maximum extent permitted by applicable law, bears no liability for the unlawful actions of Users or third parties, nor for the actions and decisions of Stripe (see Terms of Use).

11. Reporting Suspicious Activity

Users may, and are encouraged to, report suspicious activity, fraud, or violations of this Policy to support@donateopen.com. DonateOpen does not impose sanctions on Users for good-faith reports of violations.

12. Cooperation and Data Retention

DonateOpen cooperates with lawful requests from competent authorities and retains the necessary information for the periods required by applicable law and the Privacy Policy.

13. Changes to This Policy

DonateOpen reserves the right to update this Policy. The current version is published on the Platform; Users will be notified of material changes in the manner provided for in the Terms of Use.

14. Contact Information

DonateOpen Co.

Address: 16192 Coastal Hwy, Lewes, DE 19958, USA

Email: support@donateopen.com