Anti-Money Laundering Policy

1. What this policy covers

This policy explains how With A Bow helps stop the Platform being used for money laundering, terrorism financing, fraud or sanctions evasion, and what we do if we have a concern.

In this policy, "With A Bow", "we" and "us" mean Alice and Bear Holdings Pty Ltd trading as With A Bow. Words with capital letters have the meaning given in our Terms and Conditions.

2. How gifts move, and our position

Every gift given through With A Bow is processed by our payment processor, Stripe. Stripe takes each payment through our platform account and passes the gift straight on to the host's own account with Stripe, set up in the host's name. From there it is paid to the host's bank account. Our platform account keeps only our platform fee, which is the same whichever way a guest pays and covers our service and the card processing costs Stripe charges us. We do not hold gifts, pool them, keep balances for anyone or let people send money to each other.

With A Bow is not enrolled with AUSTRAC as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). We keep this under review, including as Australia's anti-money laundering laws change, and we will update this policy if our position changes.

We still take financial crime seriously, and this policy sets out the steps we take.

3. Checking who hosts are

Before any gift can be paid to a host, Stripe verifies the host's identity and bank account. Hosts give those details to Stripe directly, not to us. Stripe carries out its own checks under the laws that apply to it.

If we need to look into a concern about an account or event, we may ask the host for more information, as set out in our Terms and Conditions.

4. What we look out for

We review activity that does not look like ordinary gift-giving. Examples include:

• unusually large gifts, or an unusually large total for one event;
• many gifts in quick succession from the same source;
• events that appear fake, or where the host does not seem entitled to receive the gifts; and
• patterns that suggest someone is splitting payments to avoid attention.

We use our own review settings, based on the size of gifts and the total given from one source over a short period. These are internal risk settings, not legal reporting limits, and we do not publish them.

5. What we may do if we have a concern

If we have a concern, we may pause payments to the host while we look into it. Clause 9 of our Terms and Conditions explains how we handle a pause, including telling the host and reviewing it regularly.

When a guest disputes a payment with their bank, payments for the related event may be paused until the dispute is resolved.

If we suspect activity involves money laundering, terrorism financing, fraud or other crime, we may:

• keep the related payments paused;
• suspend the account or event;
• tell Stripe; and
• report the matter to the police or another relevant authority.

6. Records

We keep the financial records for each event for the period set out in section 14 of our Privacy Policy, including records of any concern we looked into.

7. Our team

Everyone at With A Bow who can see payment information or manage payments to hosts knows this policy and how to raise a concern.

8. Reviewing this policy

We review this policy at least once a year, and whenever our service, the way gifts move, or the law changes.

9. Contact us

If you have a question about this policy, or want to tell us about something that concerns you, email hello@withabow.com.au.