You are responsible for all of your activity in connection with the Services. You may not post or transmit, or cause to be posted or transmitted, any communication designed or intended to obtain password, account, or private information from any ShopBase user. ShopBase will not be liable for any failures in the Services or other problems which are related to your Customer Data or any equipment or service outside of ShopBase's facilities or control. You shall not use any part of the Site or Services to violate the security of any computer network, crack passwords or security encryption codes, transfer or store material that is deemed threatening or obscene, or engage in any kind of illegal activity. You will not run Maillist, Listserv, any form of auto-responder, or spam on the Site or through the Services. You will use the Services only in compliance with all applicable laws (including but not limited to policies and laws related to spamming, privacy, intellectual property, consumer and child protection, obscenity, or defamation). You represent, warrant and covenant that your use of the Services shall at all times comply with ShopBase's Anti-Spam Policy, as may be amended by ShopBase from time to time, and you will not access or use third party mailing lists in connection with preparing or distributing e-mail through the Services.
In order to maintain the security and integrity of the network for the buyers and sellers using, along with the intent of maintaining the overall security of the platform, we may take Balance Account-level or store-level actions under certain circumstances. If we detect any cases of suspicious activity or actions deemed to be in violation of ShopBase’s Terms of Service, we retain the sole discretion to take these actions, and we will notify you of any such action. To request information in connection with an account for long-term or short-term holds, you are advised to follow the instructions emailed to you with respect to the hold implementation.
Our decisions on holds are based on criteria that are essential to our management of risk and the protection of our customers and/or service providers on the ShopBase platform. Disclosure of related details are restricted and subject to our considerations without any obligation unless required by governmental authorities.
In order to facilitate actions described above and to allow us to assess the level of risk associated with your account, by opening an account on our platform, you agree to cooperate with ShopBase’s requests for financial statements and other documentation or information, when pertinent, in a timely manner.
A hold means that ShopBase temporarily holds a part or all of your Balance by rejecting one or all of your payout requests as justified by the rationale for this action. ShopBase must review many factors before imposing a rejection, including (but not limited to): account tenure, transaction activity, business type, past customer disputes, third-party claims, or authoritative proposals. Some common situations where ShopBase will hold payments may include, but are not limited to:
When a hold is placed on your Balance, the funds will remain in your Total Current Available. We will notify you via email, whenever we place a hold.
Risk-based holds generally remain in place for up to 90 to 180 days from the date the payment was received into your account or from the date of the hold implementation. We may release the hold earlier under certain circumstances, but any earlier release is conducted at our sole discretion. The hold may last longer than 180 days if the payment is challenged as a payment that should be invalidated and reversed. In this case, we will hold the payment in your account until the matter is resolved.
Sellers in violation of DMCA, article 3 in this Terms of Service must comply to these hold extension regulations: All revenues and profits generated from infringed products or campaigns published by store owners themselves on the ShopBase platform (which are being processed to payout in ShopBase Balance) will be withheld to offset the risk of disputes and litigations (for up to 90-180 days) or shall be made as requested from competent authority (if any).
We reserve the right, in our sole discretion, to seek reimbursement from a seller in any of the following circumstances: (a) we provide a refund to a buyer because a seller did not promptly deliver the goods, (b) we discover erroneous or duplicate transactions related to a seller, (c) we receive a chargeback from a buyer's credit card issuer or reversal of payment for the amount of a buyer's purchase from a seller, (d) any costs or losses in connection with refunds or compensation for orders that infringe intellectual property rights on ShopBase, or (e) a seller does not act in accordance with ShopBase’s policies.
We may obtain reimbursement of any amount owed by a seller to ShopBase by deducting said amount from future payments owed to the seller, reversing any credits to the seller’s payment account balance, charging the seller's card on file, charging the seller’s payment account, or by seeking reimbursement from the seller by any other lawful means. You hereby authorize us to use any or all of the foregoing methods to seek reimbursement. ShopBase may suspend your selling privileges at any time pending payment of your outstanding balance.
Monitor is committed to the prevention, deterrence, detection, and investigation of all forms of fraudulent advertising or abusive action conducted via advertising service providers on the ShopBase platform.
Monitor requires all users registered on ShopBase to act forthrightly and with integrity and to comply with the public resources for which they are using. It is the responsibility of all users to read and familiarize themselves with the contents of this policy and any related procedures while active on ShopBase.
For purposes of this policy, “Fraudulent advertising” & “Abusive action on advertising service providers” are defined as an advertising account’s property belonging to another party, being used without consent for advertising purposes that lead to fraudulent traffic, and might cause future reports, disputes, chargebacks, court orders, and so forth.
Prompt and thorough investigation will be conducted in any and all cases of actual or suspected fraud.
The focus of each investigation is to:
b) Process of investigation
Suspected fraud will be investigated without any undue delay, in an independent, professional manner and in the interests of all parties involved.
The violator (i.e. the potential offender), must provide sufficient evidence of their advertising activities that draws revenue on ShopBase in an appropriate manner in accordance with the ShopBase Moderation team’s request.
The investigating officer will take immediate steps to secure non-physical assets, including ShopBase accounts plus any records and all other potentially evidential documents. Said officer will ensure that appropriate controls are introduced to prevent further loss.
Forms of evidence may vary, but are not limited to:
The investigating officer will maintain detailed records of the investigation. In particular, said officer will keep a record of:
In addition, the investing officer will keep (where possible), a record of who has handled each item of evidence, categorizing evidence into the following groupings:
All interviews will be conducted in a just and proper manner and in accordance with ShopBase’s Terms of Service. Notes from any interviews will be recorded and kept in the investigation file.
The findings of the investigation will be reported to the person in charge who will determine what further action (if any) should be taken.
Upon completion of an investigation and following the conclusion of action taken, a written report shall be submitted to specialized officers containing:
As with any financial institution, there is a risk of ShopBase products and services being used to launder money and finance terrorism. [U.S] law and applicable local laws in the jurisdictions in which we operate, requires us to put training, processes and systems in place to identify, manage and mitigate this risk. We do this to protect the Group’s reputation, to comply with relevant laws and to be a good corporate citizen. Failure to do so may result in social harm, significant penalties, including legal and regulatory action.
(i) Sets out how ShopBase complies with its legislative obligations.
(ii) Applies to all business divisions and employees (permanent, temporary and third party providers) working in [U.S] and overseas.
(i) “Money laundering” is the process of hiding or disguising the source of illegally obtained (“dirty”) funds to make them appear legitimate (“clean”), e.g. by filtering them through the financial or fintech system; or by sale and purchase of goods and services.
Money laundering reduces the risk of detection and confiscation by authorities. It is just as serious as the criminal activity behind it – and preventing it can help reduce crime.
(ii) “Terrorism financing” differs from money laundering in 3 main ways:
(A) Its primary purpose is to disguise the ultimate use of the funds, as opposed to their origin.
(B) It can involve relatively small sums of money, which can have a huge impact in terms of death, destruction and disruption.
(C) Although terrorists may finance their activities through crime, legitimate funds can also be misappropriated to finance terrorism.
The AML/CTF Act provides a list of ‘designated services’, such as opening an account or making a deposit. Before receiving any of these designated services, customers will be required to provide proof of identity or similar documentation.
ShopBase is required to collect and verify this information, depending on the type of customer:
(i) “Personal” - an individual person of any nationality.
(ii) “Sole trader” - a person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business.
(iii) “Domestic company” - incorporated in [U.S], including proprietary, public and listed public companies.
(iv) “Foreign company” - incorporated outside [U.S].
(v) “Partnership” - a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit.
(vi) “Trust” - a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company.
(vii) “Association” - a group of persons who have agreed to join together in pursuit of one or more common objectives. An association can be incorporated or unincorporated.
(viii) “Registered co-operative” - a legal entity owned and controlled by the people for whom it was established and who benefit from using its services.
(ix) “Government body” - can be domestic or foreign government body.
Please note ShopBase complies with the national privacy principle. Read more about ShopBase's Privacy Statement.
Money laundering and terrorism financing (ML/TF) are sometimes detected because a customer acts or behaves in a suspicious way or by request of a competent authority.
For a ‘suspicion’ to be valid, we must have reasonable grounds to believe ML/TF activity may be occurring, unless we follow request or instruction made by the competent authority. To support this, employees receive training in identifying and reporting suspicious matters.
(i) Comply with AML/CTF legislation in the countries we operate in.
(ii) Strive to fulfil international standards as detailed in the recommendations of the Financial Action Task Force (FATF).
(iii) Work in conjunction with the [U.S] Government and the governments of the countries we operate in, and support their objectives in relation to the prevention, detection and control of ML/TF.
(iv) ShopBase may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate social responsibility.
(v) Maintain and comply with an AML/CTF program, as required by [U.S] AML/CTF legislation.
ShopBase’s Board of Directors (the Board) and Senior Management have ongoing oversight of our AML/CTF policy and procedures. All permanent and temporary employees must comply with these, attend training specific to their role, and report suspicious matters or behaviors.
We have a dedicated AML/CTF Officer or hire a professional firm or expert (MLRO), responsible for monitoring the status and effectiveness of the ShopBase’s AML/CTF risk management and compliance and reporting it to our Executive team.
The MLRO also leads a Group AML/CTF team, which maintains ShopBase’s AML/CTF policy framework, and provides subject matter expertise and advice to our businesses.
The design and implementation of the program was tailored to our ML/TF risk profile, applying specific systems and controls, including:
(i) ML/TF risk assessment.
(ii) Employee training.
(iii) Employee and customer due diligence.
(iv) Transaction monitoring.
We also report the following information to [FinCEN (Financial Crimes Enforcement Network)], [U.S]’ AML/CTF regulator:
(i) Transactions with a cash component of US$10,000 or more.
(ii) Electronic transfers of funds into or out of [U.S].
(iii) Any transactions or other activities regarded as suspicious.
You are responsible for all of your activity in connection with the Services. You may not post or transmit, or cause to be posted or transmitted, any communication designed or intended to obtain password, account, or private information from any ShopBase user. ShopBase will not be liable for any failures in the Services or other problems which are related to your Customer Data or any equipment or service outside of ShopBase's facilities or control. You shall not use any part of the Site or Services to violate the security of any computer network, crack passwords or security encryption codes, transfer or store material that is deemed threatening or obscene, or engage in any kind of illegal activity. You will not run Maillist, Listserv, any form of auto-responder, or spam on the Site or through the Services. You will use the Services only in compliance with all applicable laws (including but not limited to policies and laws related to spamming, privacy, intellectual property, consumer and child protection, obscenity, or defamation). You represent, warrant and covenant that your use of the Services shall at all times comply with ShopBase's Anti-Spam Policy, as may be amended by ShopBase from time to time, and you will not access or use third party mailing lists in connection with preparing or distributing e-mail through the Services.
In order to maintain the security and integrity of the network for the buyers and sellers using, along with the intent of maintaining the overall security of the platform, we may take Balance Account-level or store-level actions under certain circumstances. If we detect any cases of suspicious activity or actions deemed to be in violation of ShopBase’s Terms of Service, we retain the sole discretion to take these actions, and we will notify you of any such action. To request information in connection with an account for long-term or short-term holds, you are advised to follow the instructions emailed to you with respect to the hold implementation.
Our decisions on holds are based on criteria that are essential to our management of risk and the protection of our customers and/or service providers on the ShopBase platform. Disclosure of related details are restricted and subject to our considerations without any obligation unless required by governmental authorities.
In order to facilitate actions described above and to allow us to assess the level of risk associated with your account, by opening an account on our platform, you agree to cooperate with ShopBase’s requests for financial statements and other documentation or information, when pertinent, in a timely manner.
A hold means that ShopBase temporarily holds a part or all of your Balance by rejecting one or all of your payout requests as justified by the rationale for this action. ShopBase must review many factors before imposing a rejection, including (but not limited to): account tenure, transaction activity, business type, past customer disputes, third-party claims, or authoritative proposals. Some common situations where ShopBase will hold payments may include, but are not limited to:
When a hold is placed on your Balance, the funds will remain in your Total Current Available. We will notify you via email, whenever we place a hold.
Risk-based holds generally remain in place for up to 90 to 180 days from the date the payment was received into your account or from the date of the hold implementation. We may release the hold earlier under certain circumstances, but any earlier release is conducted at our sole discretion. The hold may last longer than 180 days if the payment is challenged as a payment that should be invalidated and reversed. In this case, we will hold the payment in your account until the matter is resolved.
Sellers in violation of DMCA, article 3 in this Terms of Service must comply to these hold extension regulations: All revenues and profits generated from infringed products or campaigns published by store owners themselves on the ShopBase platform (which are being processed to payout in ShopBase Balance) will be withheld to offset the risk of disputes and litigations (for up to 90-180 days) or shall be made as requested from competent authority (if any).
We reserve the right, in our sole discretion, to seek reimbursement from a seller in any of the following circumstances: (a) we provide a refund to a buyer because a seller did not promptly deliver the goods, (b) we discover erroneous or duplicate transactions related to a seller, (c) we receive a chargeback from a buyer's credit card issuer or reversal of payment for the amount of a buyer's purchase from a seller, (d) any costs or losses in connection with refunds or compensation for orders that infringe intellectual property rights on ShopBase, or (e) a seller does not act in accordance with ShopBase’s policies.
We may obtain reimbursement of any amount owed by a seller to ShopBase by deducting said amount from future payments owed to the seller, reversing any credits to the seller’s payment account balance, charging the seller's card on file, charging the seller’s payment account, or by seeking reimbursement from the seller by any other lawful means. You hereby authorize us to use any or all of the foregoing methods to seek reimbursement. ShopBase may suspend your selling privileges at any time pending payment of your outstanding balance.
Monitor is committed to the prevention, deterrence, detection, and investigation of all forms of fraudulent advertising or abusive action conducted via advertising service providers on the ShopBase platform.
Monitor requires all users registered on ShopBase to act forthrightly and with integrity and to comply with the public resources for which they are using. It is the responsibility of all users to read and familiarize themselves with the contents of this policy and any related procedures while active on ShopBase.
For purposes of this policy, “Fraudulent advertising” & “Abusive action on advertising service providers” are defined as an advertising account’s property belonging to another party, being used without consent for advertising purposes that lead to fraudulent traffic, and might cause future reports, disputes, chargebacks, court orders, and so forth.
Prompt and thorough investigation will be conducted in any and all cases of actual or suspected fraud.
The focus of each investigation is to:
b) Process of investigation
Suspected fraud will be investigated without any undue delay, in an independent, professional manner and in the interests of all parties involved.
The violator (i.e. the potential offender), must provide sufficient evidence of their advertising activities that draws revenue on ShopBase in an appropriate manner in accordance with the ShopBase Moderation team’s request.
The investigating officer will take immediate steps to secure non-physical assets, including ShopBase accounts plus any records and all other potentially evidential documents. Said officer will ensure that appropriate controls are introduced to prevent further loss.
Forms of evidence may vary, but are not limited to:
The investigating officer will maintain detailed records of the investigation. In particular, said officer will keep a record of:
In addition, the investing officer will keep (where possible), a record of who has handled each item of evidence, categorizing evidence into the following groupings:
All interviews will be conducted in a just and proper manner and in accordance with ShopBase’s Terms of Service. Notes from any interviews will be recorded and kept in the investigation file.
The findings of the investigation will be reported to the person in charge who will determine what further action (if any) should be taken.
Upon completion of an investigation and following the conclusion of action taken, a written report shall be submitted to specialized officers containing:
As with any financial institution, there is a risk of ShopBase products and services being used to launder money and finance terrorism. [U.S] law and applicable local laws in the jurisdictions in which we operate, requires us to put training, processes and systems in place to identify, manage and mitigate this risk. We do this to protect the Group’s reputation, to comply with relevant laws and to be a good corporate citizen. Failure to do so may result in social harm, significant penalties, including legal and regulatory action.
(i) Sets out how ShopBase complies with its legislative obligations.
(ii) Applies to all business divisions and employees (permanent, temporary and third party providers) working in [U.S] and overseas.
(i) “Money laundering” is the process of hiding or disguising the source of illegally obtained (“dirty”) funds to make them appear legitimate (“clean”), e.g. by filtering them through the financial or fintech system; or by sale and purchase of goods and services.
Money laundering reduces the risk of detection and confiscation by authorities. It is just as serious as the criminal activity behind it – and preventing it can help reduce crime.
(ii) “Terrorism financing” differs from money laundering in 3 main ways:
(A) Its primary purpose is to disguise the ultimate use of the funds, as opposed to their origin.
(B) It can involve relatively small sums of money, which can have a huge impact in terms of death, destruction and disruption.
(C) Although terrorists may finance their activities through crime, legitimate funds can also be misappropriated to finance terrorism.
The AML/CTF Act provides a list of ‘designated services’, such as opening an account or making a deposit. Before receiving any of these designated services, customers will be required to provide proof of identity or similar documentation.
ShopBase is required to collect and verify this information, depending on the type of customer:
(i) “Personal” - an individual person of any nationality.
(ii) “Sole trader” - a person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business.
(iii) “Domestic company” - incorporated in [U.S], including proprietary, public and listed public companies.
(iv) “Foreign company” - incorporated outside [U.S].
(v) “Partnership” - a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit.
(vi) “Trust” - a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company.
(vii) “Association” - a group of persons who have agreed to join together in pursuit of one or more common objectives. An association can be incorporated or unincorporated.
(viii) “Registered co-operative” - a legal entity owned and controlled by the people for whom it was established and who benefit from using its services.
(ix) “Government body” - can be domestic or foreign government body.
Please note ShopBase complies with the national privacy principle. Read more about ShopBase's Privacy Statement.
Money laundering and terrorism financing (ML/TF) are sometimes detected because a customer acts or behaves in a suspicious way or by request of a competent authority.
For a ‘suspicion’ to be valid, we must have reasonable grounds to believe ML/TF activity may be occurring, unless we follow request or instruction made by the competent authority. To support this, employees receive training in identifying and reporting suspicious matters.
(i) Comply with AML/CTF legislation in the countries we operate in.
(ii) Strive to fulfil international standards as detailed in the recommendations of the Financial Action Task Force (FATF).
(iii) Work in conjunction with the [U.S] Government and the governments of the countries we operate in, and support their objectives in relation to the prevention, detection and control of ML/TF.
(iv) ShopBase may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate social responsibility.
(v) Maintain and comply with an AML/CTF program, as required by [U.S] AML/CTF legislation.
ShopBase’s Board of Directors (the Board) and Senior Management have ongoing oversight of our AML/CTF policy and procedures. All permanent and temporary employees must comply with these, attend training specific to their role, and report suspicious matters or behaviors.
We have a dedicated AML/CTF Officer or hire a professional firm or expert (MLRO), responsible for monitoring the status and effectiveness of the ShopBase’s AML/CTF risk management and compliance and reporting it to our Executive team.
The MLRO also leads a Group AML/CTF team, which maintains ShopBase’s AML/CTF policy framework, and provides subject matter expertise and advice to our businesses.
The design and implementation of the program was tailored to our ML/TF risk profile, applying specific systems and controls, including:
(i) ML/TF risk assessment.
(ii) Employee training.
(iii) Employee and customer due diligence.
(iv) Transaction monitoring.
We also report the following information to [FinCEN (Financial Crimes Enforcement Network)], [U.S]’ AML/CTF regulator:
(i) Transactions with a cash component of US$10,000 or more.
(ii) Electronic transfers of funds into or out of [U.S].
(iii) Any transactions or other activities regarded as suspicious.
You are responsible for all of your activity in connection with the Services. You may not post or transmit, or cause to be posted or transmitted, any communication designed or intended to obtain password, account, or private information from any ShopBase user. ShopBase will not be liable for any failures in the Services or other problems which are related to your Customer Data or any equipment or service outside of ShopBase's facilities or control. You shall not use any part of the Site or Services to violate the security of any computer network, crack passwords or security encryption codes, transfer or store material that is deemed threatening or obscene, or engage in any kind of illegal activity. You will not run Maillist, Listserv, any form of auto-responder, or spam on the Site or through the Services. You will use the Services only in compliance with all applicable laws (including but not limited to policies and laws related to spamming, privacy, intellectual property, consumer and child protection, obscenity, or defamation). You represent, warrant and covenant that your use of the Services shall at all times comply with ShopBase's Anti-Spam Policy, as may be amended by ShopBase from time to time, and you will not access or use third party mailing lists in connection with preparing or distributing e-mail through the Services.
In order to maintain the security and integrity of the network for the buyers and sellers using, along with the intent of maintaining the overall security of the platform, we may take Balance Account-level or store-level actions under certain circumstances. If we detect any cases of suspicious activity or actions deemed to be in violation of ShopBase’s Terms of Service, we retain the sole discretion to take these actions, and we will notify you of any such action. To request information in connection with an account for long-term or short-term holds, you are advised to follow the instructions emailed to you with respect to the hold implementation.
Our decisions on holds are based on criteria that are essential to our management of risk and the protection of our customers and/or service providers on the ShopBase platform. Disclosure of related details are restricted and subject to our considerations without any obligation unless required by governmental authorities.
In order to facilitate actions described above and to allow us to assess the level of risk associated with your account, by opening an account on our platform, you agree to cooperate with ShopBase’s requests for financial statements and other documentation or information, when pertinent, in a timely manner.
A hold means that ShopBase temporarily holds a part or all of your Balance by rejecting one or all of your payout requests as justified by the rationale for this action. ShopBase must review many factors before imposing a rejection, including (but not limited to): account tenure, transaction activity, business type, past customer disputes, third-party claims, or authoritative proposals. Some common situations where ShopBase will hold payments may include, but are not limited to:
When a hold is placed on your Balance, the funds will remain in your Total Current Available. We will notify you via email, whenever we place a hold.
Risk-based holds generally remain in place for up to 90 to 180 days from the date the payment was received into your account or from the date of the hold implementation. We may release the hold earlier under certain circumstances, but any earlier release is conducted at our sole discretion. The hold may last longer than 180 days if the payment is challenged as a payment that should be invalidated and reversed. In this case, we will hold the payment in your account until the matter is resolved.
Sellers in violation of DMCA, article 3 in this Terms of Service must comply to these hold extension regulations: All revenues and profits generated from infringed products or campaigns published by store owners themselves on the ShopBase platform (which are being processed to payout in ShopBase Balance) will be withheld to offset the risk of disputes and litigations (for up to 90-180 days) or shall be made as requested from competent authority (if any).
We reserve the right, in our sole discretion, to seek reimbursement from a seller in any of the following circumstances: (a) we provide a refund to a buyer because a seller did not promptly deliver the goods, (b) we discover erroneous or duplicate transactions related to a seller, (c) we receive a chargeback from a buyer's credit card issuer or reversal of payment for the amount of a buyer's purchase from a seller, (d) any costs or losses in connection with refunds or compensation for orders that infringe intellectual property rights on ShopBase, or (e) a seller does not act in accordance with ShopBase’s policies.
We may obtain reimbursement of any amount owed by a seller to ShopBase by deducting said amount from future payments owed to the seller, reversing any credits to the seller’s payment account balance, charging the seller's card on file, charging the seller’s payment account, or by seeking reimbursement from the seller by any other lawful means. You hereby authorize us to use any or all of the foregoing methods to seek reimbursement. ShopBase may suspend your selling privileges at any time pending payment of your outstanding balance.
Monitor is committed to the prevention, deterrence, detection, and investigation of all forms of fraudulent advertising or abusive action conducted via advertising service providers on the ShopBase platform.
Monitor requires all users registered on ShopBase to act forthrightly and with integrity and to comply with the public resources for which they are using. It is the responsibility of all users to read and familiarize themselves with the contents of this policy and any related procedures while active on ShopBase.
For purposes of this policy, “Fraudulent advertising” & “Abusive action on advertising service providers” are defined as an advertising account’s property belonging to another party, being used without consent for advertising purposes that lead to fraudulent traffic, and might cause future reports, disputes, chargebacks, court orders, and so forth.
Prompt and thorough investigation will be conducted in any and all cases of actual or suspected fraud.
The focus of each investigation is to:
b) Process of investigation
Suspected fraud will be investigated without any undue delay, in an independent, professional manner and in the interests of all parties involved.
The violator (i.e. the potential offender), must provide sufficient evidence of their advertising activities that draws revenue on ShopBase in an appropriate manner in accordance with the ShopBase Moderation team’s request.
The investigating officer will take immediate steps to secure non-physical assets, including ShopBase accounts plus any records and all other potentially evidential documents. Said officer will ensure that appropriate controls are introduced to prevent further loss.
Forms of evidence may vary, but are not limited to:
The investigating officer will maintain detailed records of the investigation. In particular, said officer will keep a record of:
In addition, the investing officer will keep (where possible), a record of who has handled each item of evidence, categorizing evidence into the following groupings:
All interviews will be conducted in a just and proper manner and in accordance with ShopBase’s Terms of Service. Notes from any interviews will be recorded and kept in the investigation file.
The findings of the investigation will be reported to the person in charge who will determine what further action (if any) should be taken.
Upon completion of an investigation and following the conclusion of action taken, a written report shall be submitted to specialized officers containing:
As with any financial institution, there is a risk of ShopBase products and services being used to launder money and finance terrorism. [U.S] law and applicable local laws in the jurisdictions in which we operate, requires us to put training, processes and systems in place to identify, manage and mitigate this risk. We do this to protect the Group’s reputation, to comply with relevant laws and to be a good corporate citizen. Failure to do so may result in social harm, significant penalties, including legal and regulatory action.
(i) Sets out how ShopBase complies with its legislative obligations.
(ii) Applies to all business divisions and employees (permanent, temporary and third party providers) working in [U.S] and overseas.
(i) “Money laundering” is the process of hiding or disguising the source of illegally obtained (“dirty”) funds to make them appear legitimate (“clean”), e.g. by filtering them through the financial or fintech system; or by sale and purchase of goods and services.
Money laundering reduces the risk of detection and confiscation by authorities. It is just as serious as the criminal activity behind it – and preventing it can help reduce crime.
(ii) “Terrorism financing” differs from money laundering in 3 main ways:
(A) Its primary purpose is to disguise the ultimate use of the funds, as opposed to their origin.
(B) It can involve relatively small sums of money, which can have a huge impact in terms of death, destruction and disruption.
(C) Although terrorists may finance their activities through crime, legitimate funds can also be misappropriated to finance terrorism.
The AML/CTF Act provides a list of ‘designated services’, such as opening an account or making a deposit. Before receiving any of these designated services, customers will be required to provide proof of identity or similar documentation.
ShopBase is required to collect and verify this information, depending on the type of customer:
(i) “Personal” - an individual person of any nationality.
(ii) “Sole trader” - a person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business.
(iii) “Domestic company” - incorporated in [U.S], including proprietary, public and listed public companies.
(iv) “Foreign company” - incorporated outside [U.S].
(v) “Partnership” - a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit.
(vi) “Trust” - a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company.
(vii) “Association” - a group of persons who have agreed to join together in pursuit of one or more common objectives. An association can be incorporated or unincorporated.
(viii) “Registered co-operative” - a legal entity owned and controlled by the people for whom it was established and who benefit from using its services.
(ix) “Government body” - can be domestic or foreign government body.
Please note ShopBase complies with the national privacy principle. Read more about ShopBase's Privacy Statement.
Money laundering and terrorism financing (ML/TF) are sometimes detected because a customer acts or behaves in a suspicious way or by request of a competent authority.
For a ‘suspicion’ to be valid, we must have reasonable grounds to believe ML/TF activity may be occurring, unless we follow request or instruction made by the competent authority. To support this, employees receive training in identifying and reporting suspicious matters.
(i) Comply with AML/CTF legislation in the countries we operate in.
(ii) Strive to fulfil international standards as detailed in the recommendations of the Financial Action Task Force (FATF).
(iii) Work in conjunction with the [U.S] Government and the governments of the countries we operate in, and support their objectives in relation to the prevention, detection and control of ML/TF.
(iv) ShopBase may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate social responsibility.
(v) Maintain and comply with an AML/CTF program, as required by [U.S] AML/CTF legislation.
ShopBase’s Board of Directors (the Board) and Senior Management have ongoing oversight of our AML/CTF policy and procedures. All permanent and temporary employees must comply with these, attend training specific to their role, and report suspicious matters or behaviors.
We have a dedicated AML/CTF Officer or hire a professional firm or expert (MLRO), responsible for monitoring the status and effectiveness of the ShopBase’s AML/CTF risk management and compliance and reporting it to our Executive team.
The MLRO also leads a Group AML/CTF team, which maintains ShopBase’s AML/CTF policy framework, and provides subject matter expertise and advice to our businesses.
The design and implementation of the program was tailored to our ML/TF risk profile, applying specific systems and controls, including:
(i) ML/TF risk assessment.
(ii) Employee training.
(iii) Employee and customer due diligence.
(iv) Transaction monitoring.
We also report the following information to [FinCEN (Financial Crimes Enforcement Network)], [U.S]’ AML/CTF regulator:
(i) Transactions with a cash component of US$10,000 or more.
(ii) Electronic transfers of funds into or out of [U.S].
(iii) Any transactions or other activities regarded as suspicious.
