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 campaign category, the coordinator must complete document-level identity and sanctions verification through a specialist compliance provider. The process may include a government-issued identity document, biometric liveness, face matching, and device or network risk analysis. One approved verification normally covers every campaign that coordinator runs. No withdrawal is released for an unverified coordinator, and an unsuccessful or inconclusive result keeps withdrawals locked until the case is resolved.
(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. Crossing the enhanced-due-diligence thresholds described below is satisfied by the identity verification in (b); coordinators whose campaign profile triggers manual review, or whose verification compliance judges insufficient for the risk presented, are additionally asked for supporting documentation before further withdrawals release. The dashboard tells them clearly when this happens.
Donor and beneficiary KYC triggers.
SenteMe applies risk-based identity and AML checks to donors and beneficiaries. Verification may be required before a payment or payout based on the amount, cumulative activity, changes in recipient information, or other risk indicators. Additional documents or recipient confirmation may also be required. These checks can delay or prevent a contribution or payout. Exact security thresholds and detection rules are confidential and may be adjusted as risks and legal requirements change.
Sanctions screening.
SenteMe uses specialist identity and compliance services to screen relevant organisers, donors and payout recipients against applicable sanctions and watchlists, including the US Treasury OFAC, UN Security Council and European Union consolidated lists. Screening must be completed before the relevant contribution or withdrawal can proceed. A possible match blocks money movement and triggers compliance review. A confirmed match results in account and campaign restrictions, a payout freeze, and reporting or return of funds where legally permitted. Licensed payment partners also apply their own regulated sanctions controls before moving funds.
Prohibited jurisdictions and independent IP blocking.
SenteMe does not support or knowingly conduct transactions involving Cuba, Iran, North Korea, Syria, the Crimea region including Sevastopol, the Donetsk region, or the Luhansk region. Campaign creation and payout destinations are limited to supported countries and payment corridors. SenteMe also operates independent IP-based and application-level controls to block access and transactions involving prohibited jurisdictions. These controls are operated by Mea Global Inc and do not rely solely on a payment partner.
Review model.
A campaign must describe an allowed cause and receive approval before public listing. A private link may accept contributions before that review. Manual campaign review is separate from the identity verification required before withdrawal. SenteMe may request supporting documents, suspend a campaign or pause withdrawals during a review. A badge does not guarantee how funds will be used or the outcome. Report a suspicious campaign from its page.
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.
SenteMe uses automated and manual risk monitoring across contributions, accounts, campaigns and payout recipients. The controls consider transaction size, cumulative activity, payment-attempt patterns, identity or location inconsistencies, recipient changes, device and network signals, and other indicators of unusual activity. Monitoring may require step-up verification, supporting documents or manual review, and may delay or block a contribution or withdrawal. Exact thresholds and detection logic are confidential to protect the effectiveness of these controls.
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 details, withdrawal references and sanctions-screening results for seven years from the date of the last transaction on the account. Required identity-verification records are retained for the same period. Records are encrypted at rest and access is restricted to authorised staff and systems. After the seven-year period, records are deleted according to our retention schedule unless they are subject to 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.
