PUSHPAY ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING STATEMENT

Last Update: November 1, 2018

Pushpay is committed to full compliance with all applicable laws and regulations regarding Anti- Money Laundering.  Pushpay’s policy is to prevent people engaged in money laundering, fraud, and other financial crimes, including terrorist financing, from using Pushpay.

Pushpay has robust policies and procedures to detect, prevent and report suspicious activity. To comply with OFAC (Office of Foreign Asset Control) requirements, and global sanctions, we screen our customer accounts against government watch lists. In addition, we may request that you provide us with documentation to help prove your identity or for business verification purposes. We report suspicious transactions to our downstream partners and as required by law.

How does this impact me?

As part of our Anti-Money Laundering procedures, we collect information from you to satisfy Know Your Customer requirements. This means that we may request information from you due to a specific identification requirement or as a result of our watch list screening process. We may ask you to provide documentation to help confirm your identity or provide additional information regarding yourself and your organization. We may also refuse to provide some or all of our services if your account is deemed high risk, which for live accounts may result in a unsettled funds being placed on hold, or an inability to accept or process payments.

When is this information requested?

We may ask for this information during account opening or as part of our account review process which we periodically conduct on our existing customers.

Compliance with Laws

In performing its obligations under this Agreement, each party agrees to comply with all laws and regulations applicable to it. You further agree to cooperate and provide information requested by us or our Processing Partners, as we determine necessary, to facilitate compliance with any applicable law including without limitation the rules and regulations promulgated by the Office of Foreign Assets Control of the US Department of the Treasury. You further acknowledge and agree that you will not use your accounts and/or the Services for illegal transactions, for example, those prohibited by the Unlawful Internet Gambling Enforcement Act, 31 U.S.C. Section 5361 et seq, as may be amended from time to time, or those involving any Person listed on the U.S. Department of Treasury, Office of Foreign Assets Control, Specially Designated Nationals and Blocked Persons List (available at www.treas.gov/ofac) or the U.S. Department of State’s Terrorist Exclusion List (available at www.state.gov), or for the processing and acceptance of transactions in certain jurisdictions pursuant to 31 CFR Part 500 et seq. and other laws enforced by the Office of Foreign Assets Control (“OFAC”) or in connection with illegal activity of any kind.

Important Merchant Responsibilities:

a) Ensure compliance with cardholder data security and storage requirements.
b) Maintain fraud and Chargebacks below card organization thresholds.
c) Review and understand the terms of the Covered Agreements.
d) Comply with card organization Rules and applicable law and regulations.
e) You may download “Visa Regulations” from Visa’s website at: https://usa.visa.com/support/merchant.html.
f) You may download “MasterCard Regulations” from MasterCard’s website at: http://www.mastercard.com/us/merchant/support /rules.html.
g) You may download “American Express Merchant Operating Guide” from American Express’ website at: www.americanexpress.com/merchantopguide.

Card Organization Rules and Compliance

You agree to follow all requirements in connection with each card transaction and to comply with all applicable Card Organization Rules, including without limitation, the data security requirements described in Part I, Section 5. We may amend our agreements with you from time to time without prior notice, effective immediately upon posting the updates in our Legal Center to reflect changes in the Card Organization Rules or for security or other compliance related reasons. You are responsible for staying apprised of all applicable changes to the Card Organization Rules and maintaining compliance with the Card Organization Rules. Card Organization Rules may be available on web sites such as as http://usa.visa.com/merchants/merchant-support/international-operating-regulations.jsp and http://www.mastercard.com/us/merchant/support/rules.html. These links may change from time to time.

The parties will comply with all laws, regulations, and rules (including ACH’s network rules, requirements, and standards and the NACHA Rules) that are applicable to their respective performance obligations. Pushpay Processing Inc. acknowledges that it is the Originator under the NACHA Rules with respect to its transactions and agrees to comply with its obligations as an Originator.