Purpose.
This is SenteMe's Anti-Money-Laundering and Counter-Financing-of-Terrorism (AML / CFT) policy. SenteMe is operated by Mea Global Inc, a Delaware-registered corporation. SenteMe is a platform that sits on top of licensed third-party payment partners, the regulated AML / CFT obligations under each operating country's money-services law fall on the licensed payment partner that actually moves the funds, not on SenteMe. We adopt this policy voluntarily, on top of the partner's regulated obligations, because surface-level controls in the SenteMe product (campaign-creation review, transaction monitoring, the new-recipient confirmation gate, withdrawal thresholds, sanctions screening on recipient phone numbers) materially reduce the risk that the platform is used for laundering or terrorism financing, and that protects contributors, coordinators, our payment partners, and the regulators they answer to. This policy is voluntary supplementary controls, not a claim that SenteMe itself is a licensed money services business. Where a partner's regulated policy is stricter than ours on a given point, the stricter standard wins for traffic moving through that partner; this document otherwise governs SenteMe's own platform-level controls.
Who and what it covers.
The policy applies to: (a) every coordinator who creates a campaign on SenteMe, (b) every contributor who sends money to a campaign, (c) every beneficiary who receives a withdrawal from a campaign, and (d) every member of Mea Global Inc staff or contractors who has access to SenteMe systems. It covers the full payment lifecycle: account creation, contribution receipt, ledger transparency, withdrawal authorisation, and post-withdrawal record retention.
Coordinator identity verification.
Identity collection happens in three stages, with the strongest control firing before any money can leave the platform.
(a) At sign-up we collect and store the coordinator's legal name, country of residence, email address, and mobile-money phone number. The email address is verified by confirmation link before the account becomes usable. The mobile-money number is format-validated and bound to the coordinator's chosen country at this stage.
(b) Before the first withdrawal on any campaign, regardless of the amount raised or the campaign category, the coordinator must complete document-level identity verification: a government-issued identity document is captured and machine-read, a biometric liveness check confirms a live person is present, the selfie is face-matched against the document photo, and device and network signals are analysed for fraud patterns. The verification is processed by our specialised identity-verification provider (Didit) and applies platform-wide: one approved verification covers every campaign that coordinator runs. No withdrawal is released for an unverified coordinator, and a declined verification blocks withdrawals until compliance review resolves the case. This control is deliberately universal: it was introduced after a fraud case in July 2026 in which threshold-based checks alone allowed a bad actor to drain a campaign through frequent small withdrawals.
(c) At payout time, the licensed mobile-money payment partner that processes the payout itself verifies that the recipient phone is a real, registered SIM under its operating-country rules (Bank of Uganda, Central Bank of Kenya, BNR for Rwanda, and equivalents). A payout to an unregistered, unreachable, or sanctioned SIM is rejected at the rails before any money moves. The mobile-money number was also KYC'd at carrier-registration time, which provides the underlying SIM-to-person binding.
When a withdrawal is initiated to a recipient phone the campaign has not paid before, the dashboard surfaces an additional confirmation step that the coordinator must explicitly tick before the disbursement releases. Coordinators whose campaign profile triggers manual review, or who cross the enhanced-KYC threshold described below, are additionally asked for supporting documentation before further withdrawals release. The dashboard tells them clearly when this happens.
Beneficiary KYC triggers.
When a withdrawal goes to a phone number the campaign has not paid before, an extra confirmation step blocks the withdrawal until the coordinator explicitly ticks an acknowledgement that they have verified the recipient with the beneficiary themselves. Additional KYC documentation is required from the coordinator before further withdrawals release when any of these thresholds is crossed: (a) the campaign has raised more than USD 2,000 cumulative (computed at the prevailing local-currency rate), or (b) a single contribution exceeds USD 500, or (c) the coordinator has initiated more than five withdrawals to distinct phone numbers in a 7-day window. Documentation we ask for: government-issued ID of the coordinator, written description of the beneficiary's relationship to the coordinator, and proof of the underlying real-world need (e.g. hospital invoice, school fee statement, photo of the funeral programme).
Sanctions screening.
Every payout is screened against the US Treasury OFAC consolidated list, the UN Security Council consolidated list, and the European Union consolidated list before the funds release. The screening is performed by our licensed mobile-money payment partner, which is regulated to maintain and apply these lists in real time as part of its money-services licence in each operating country. A positive match blocks the payout immediately, returns an error to the SenteMe dashboard, and triggers a manual review by the SenteMe compliance lead. A coordinator whose name positively matches a sanctions list will have their account closed and any held funds returned to contributors through the rails where they can be returned. Phase 2 of our compliance roadmap adds a SenteMe-run pre-check at sign-up using the same public lists, so a sanctioned coordinator is rejected before they ever publish a campaign rather than only at withdrawal, see the "Policy review" section below for the planned timing.
Review model.
To keep barriers to entry low, campaigns go live for contributions immediately on publish and may begin accepting contributions straight away. At creation, the Creator must select one of the Permitted Categories, a campaign cannot be created without choosing a category. This forces each campaign to self-classify, makes obviously out-of-scope causes easy to catch, and lets the review focus on whether the campaign genuinely fits the category it selected. Every newly published campaign enters SenteMe's Trust & Safety review queue; the review aim is hours not days. Withdrawals are controlled by two independent gates rather than by the review clock. First, no withdrawal is released on any campaign until the coordinator has completed the document-level identity verification described above, so an anonymous actor can never extract funds. Second, SenteMe can freeze the payouts of any individual campaign at any time, during review, on a monitoring alert, or on a community report, without touching the campaign page or its ability to receive contributions; a frozen campaign's funds remain in the licensed payment partner's segregated account. A campaign that does not fall within its selected Permitted Category, or that falls within a Prohibited Category, is suspended; held contributions remain in the segregated account and are returned to contributors via the payment partner's refund rails. This pairs immediate go-live for contributors with identity-verified, freezable payout controls. Vetting also applies at the creation phase itself: every campaign must self-classify into a permitted category (prohibited categories are blocked at creation), launches private and link-only until a human review approves public listing, carries a self-attestation recorded with timestamp, network address and device identifier, and, in the medical and education categories, must hold cause documentation before any withdrawal. We are additionally rolling out automated screening of new campaign content against prohibited-category and fraud signals at the moment of creation, device-based detection of serial fraudulent creators, and a pre-payment confirmation screen that tells every contributor the campaign name, the organiser name, and that their payment is a contribution to a fundraiser, not a purchase.
Prohibited campaign categories.
We do not accept campaigns for any of the categories on our prohibited list. The list mirrors the standard prohibited categories every licensed mobile-money aggregator we work with enforces, plus our own additions. It is reviewed against our payment partners' published policies and updated when those policies change. The list is enforced both at campaign creation (the description and selected template are reviewed automatically and flagged for manual review where signals match) and post-creation when a community report or our own monitoring flags a campaign. Prohibited categories: sanctioned entities and individuals; gambling and betting in all forms; controlled drugs and psychotropic substances; pyramid schemes, multi-level marketing, "get rich quick" schemes, and Ponzi structures; defence, weapons and dual-use military equipment; escort services and adult entertainment; unregistered pharmacies and the sale of prescription medicines; shell companies with no real-world operating activity; counterfeit goods and intellectual-property-infringing merchandise; charities that are not registered under their local Charity Commission or equivalent regulator.
Transaction monitoring.
We run automated monitoring against every contribution and every withdrawal for the following patterns: rapid-fire small contributions from many different phone numbers (potential layering), unusually large single contributions from a contributor with no prior history on the platform (potential placement), repeated withdrawals to a single phone number not previously paid (potential structuring), withdrawals to countries that the campaign's stated location does not justify, and behaviour that diverges from the campaign's declared template (e.g. a funeral-template campaign making 50 withdrawals to different numbers over a week). Alerts go to the SenteMe compliance lead's queue; campaigns flagged are paused for review within 24 hours.
Suspicious activity reporting.
When a monitoring alert or a manual review concludes that a campaign or contribution is suspicious, SenteMe files a Suspicious Transaction Report (STR) with Uganda's Financial Intelligence Authority within the statutory window. The mobile-money partner that processed the relevant transactions is notified in parallel, as our payment partner agreements require. In cases involving US sanctions, OFAC is notified through Mea Global Inc's US compliance counsel. We do not tip off the coordinator or the contributors during an open STR, the account may be paused without specific reason during that window, by law.
Record retention.
We retain transaction records (contributor identifiers, amounts, timestamps, recipient phone numbers, withdrawal references, sanctions-screening results) for seven years from the date of the last transaction on the account. KYC documentation collected from coordinators for elevated-threshold campaigns is retained for the same period. Records are stored encrypted at rest in our Supabase database (EU region) with row-level security restricting access to authorised SenteMe staff. After the seven-year window, records are purged on a quarterly schedule unless held under a legal hold.
Staff training and accountability.
Every Mea Global Inc team member with access to SenteMe systems completes AML / CFT training at onboarding and again annually. The SenteMe Compliance Lead is named in the company's internal compliance manual and is the point of contact for the FIA, the compliance teams at our mobile-money partners, and OFAC where applicable. The Compliance Lead reports quarterly to the company directors on monitoring volumes, alerts, STRs filed, and any sanctions-list updates that affected platform use.
Policy review.
This policy is reviewed at least annually, and out-of-cycle whenever (a) any of our mobile-money or other payment partners materially updates their own AML / CFT requirements, (b) any of our operating-country regulators publishes new guidance for non-bank payment service providers, or (c) we add a payment corridor in a new country or a new type of rail (card, bank, stablecoin). Material changes will be reflected in the "Last updated" date at the top of this page and announced to coordinators by email.
How to reach us.
For questions about this policy, to report a suspicious campaign, or for compliance-related correspondence from a regulator: [email protected]. We aim to acknowledge regulator correspondence within one business day and to respond substantively within five business days unless the matter is more complex.
