Effective Date: [1 January 2026]

1. Policy Statement
   Initiate Global Foundation, Inc. (“Initiate Global” or the “Foundation”) is committed to preventing its crowdfunding platform from being used for money laundering, terrorist financing, fraud, or other unlawful financial activities.

   As a non-stock, non-profit organization acting as a fundraising conduit between donors and campaign creators, Initiate Global implements a risk-based AML/CTF framework consistent with:

   1. Republic Act No. 9160 (Anti-Money Laundering Act of 2001), as amended;
   2. Applicable AMLC rules and issuances;
   3. Relevant regulations affecting nonprofit organizations and online platforms;
   4. International standards set by the Financial Action Task Force (FATF).

   Where financial transactions are processed through regulated financial institutions or payment processors, Initiate Global cooperates fully with such partners to ensure AML/CTF compliance.

2. Objectives and Scope
   2.1 Objectives
   This Policy aims to:
   
   1. Prevent misuse of the platform for illicit financial activity;
   2. Identify and verify users through appropriate due diligence;
   3. Detect and escalate suspicious transactions;
   4. Maintain adequate records for audit and regulatory purposes;
   5. Promote a culture of compliance and ethical conduct.

   2.2 Scope
   This Policy applies to:

   1. Campaign Creators;
   2. Donors and Backers;
   3. Trustees, officers, employees, and volunteers;
   4. Third-party service providers (e.g., payment processors, KYC vendors);
   5. Any person or entity transacting through the platform.
3. AML Governance Structure
   3.1 AML Compliance Officer
   Initiate Global shall designate an AML Compliance Officer (which may be the DPO or a separate officer), responsible for:
   
   1. Oversight of AML/CTF implementation;
   2. Risk assessment and policy review;
   3. Escalation and investigation of suspicious activity;
   4. Coordination with payment partners and authorities;
   5. Maintaining AML documentation and records.

   The AML Officer reports to senior management and/or the Board of Trustees.

   3.2 Risk-Based Approach
   Initiate Global adopts a risk-based approach, meaning enhanced scrutiny is applied to higher-risk users, campaigns, jurisdictions, and transaction patterns.

4. Know Your Customer (KYC) and Customer Due Diligence (CDD)
   4.1 Campaign Creator Verification
   Before a campaign is approved, Creators must complete identity verification, including:
   
   1. Valid government-issued identification;
   2. Proof of address;
   3. For juridical entities: registration documents (SEC, DTI, CDA), beneficial ownership declarations, and authorized signatory details.

   Where risk indicators are present (e.g., foreign ownership, complex structures, high-risk sectors), Enhanced Due Diligence (EDD) may be required.

   4.2 Donor Verification
   While routine donations may not require full identity verification, additional due diligence may be triggered where:

   1. A single donation exceeds a defined internal threshold (e.g., ₱500,000 or equivalent);
   2. Multiple structured donations appear designed to evade monitoring;
   3. Transactions originate from high-risk jurisdictions;
   4. Other red flags are detected.

   Enhanced measures may include:

   1. Collection of identification documents;
   2. Source-of-funds declaration;
   3. Additional sanctions and PEP screening.

   4.3 Ongoing Monitoring
   Initiate Global monitors transaction patterns using a combination of automated tools and manual oversight to detect:

   1. Structuring or smurfing behavior;
   2. Unusual spikes in campaign inflows;
   3. Rapid or repeated withdrawals inconsistent with campaign objectives;
   4. Cross-border transfers inconsistent with stated project purposes.
5. Sanctions Screening and Politically Exposed Persons (PEPs)
   Initiate Global screens campaign creators and high-value donors against:
   
   1. United Nations sanctions lists;
   2. OFAC and other international sanctions databases (where applicable);
   3. Domestic watchlists and advisories;
   4. Politically Exposed Persons (PEP) databases.

   If a match or potential match is identified:

   1. Enhanced Due Diligence shall be conducted;
   2. Transactions may be paused or restricted;
   3. The matter may be escalated to payment partners or competent authorities where legally required.

   Users associated with sanctioned entities shall be denied access to the platform.

6. Source of Funds and Withdrawal Controls
   Initiate Global may require campaign creators to substantiate legitimacy of funds or withdrawals, including:
   
   1. Bank statements;
   2. Supporting contracts or invoices;
   3. Written explanation for unusual transaction activity.

   Failure to provide satisfactory documentation may result in:

   1. Suspension of withdrawals;
   2. Freezing of undistributed funds;
   3. Termination of account;
   4. Escalation to relevant authorities through appropriate channels.
7. Suspicious Transaction Handling
   While Initiate Global itself may not be classified as a “covered institution” under AMLA unless otherwise designated, it shall:
   
   1. Cooperate fully with regulated payment processors and banks that have reporting obligations;
   2. Provide requested documentation for lawful investigations;
   3. Escalate suspicious matters internally to the AML Officer;
   4. Preserve transaction records and audit trails.

   Where legally required or upon official request, relevant information shall be provided to competent authorities in accordance with applicable law.

8. Record Retention
   Initiate Global shall retain:
   
   1. KYC documentation;
   2. Transaction records;
   3. Monitoring logs;
   4. Escalation and investigation reports;
   5. Sanctions screening results.

   Records shall be retained for at least five (5) years from the date of the last transaction or campaign closure, or longer if required by law or investigation.

   All records shall be securely stored in compliance with the Data Privacy Act of 2012.

9. Staff Training and Awareness
   All relevant personnel shall receive periodic AML/CTF training covering:
   
   1. Identification of red flags;
   2. Escalation procedures;
   3. Recordkeeping requirements;
   4. Data sharing boundaries;
   5. Ethical and compliance culture.

   Training shall occur at onboarding and at least annually thereafter.

10. Third-Party Service Providers
    Third-party partners (e.g., payment gateways, KYC providers) must:
    
    1. Maintain AML/CTF programs consistent with applicable law;
    2. Execute written agreements incorporating compliance obligations;
    3. Provide assurance of regulatory compliance;
    4. Promptly notify Initiate Global of suspicious activity involving shared users.
11. Non-Compliance and Enforcement
    Failure to comply with AML/CTF requirements may result in:
    
    1. Account suspension or termination;
    2. Withholding or freezing of funds;
    3. Denial of campaign approval;
    4. Referral to competent authorities where appropriate.

    Initiate Global reserves the right to pursue civil remedies where fraud or misrepresentation is established.

12. Policy Review and Continuous Improvement
    This Policy shall be reviewed at least annually and updated to reflect:
    
    1. Legislative or regulatory changes;
    2. FATF guidance;
    3. Emerging financial crime risks;
    4. Operational developments.

Prepared by Management, 2026