Anti-Money Laundering (AML) Policy

1. Purpose

ReFounder is committed to preventing money laundering, terrorist financing and other financial crime. This policy describes the controls we apply across the marketplace and the obligations every user accepts when they sign up.

2. Regulatory framework

ReFounder relies on a regulated payment institution (Stripe Payments) for all card processing, payouts and fund custody. Stripe performs Know-Your-Customer (KYC) and Know-Your-Business (KYB) checks on every seller before payouts can be released, in line with the EU 4th and 5th Anti-Money Laundering Directives (AMLD4/AMLD5), the Finnish Money Laundering Act (Laki rahanpesun ja terrorismin rahoittamisen estämisestä 444/2017) and applicable PSD2 obligations.

3. Seller verification (KYC/KYB)

• Every seller must complete identity verification with Stripe before publishing a listing or receiving payouts.
• Sellers must provide a verified email address and a bank account in their own (or their business's) name.
• For business sellers, beneficial-ownership information is collected and verified.
• Sellers warrant that all assets listed are lawfully owned by them, free from encumbrance, and lawfully transferable.

4. Transaction monitoring

• Stripe Radar screens every payment for fraud and suspicious patterns before authorization.
• ReFounder applies in-platform monitoring for unusual activity (rapid relisting, repeated chargebacks, price anomalies, mismatched delivery patterns).
• In-chat sharing of email addresses, phone numbers, bank account / IBAN numbers and external URLs is automatically blocked to prevent off-platform settlement.
• Listings are subject to manual moderation before going live.

5. Prohibited transactions

The following are strictly prohibited on ReFounder and will result in immediate account termination, frozen funds and, where applicable, a suspicious activity report (SAR) to the Finnish Financial Intelligence Unit (rahanpesun selvittelykeskus):

• Transactions involving sanctioned individuals, entities or jurisdictions (EU, UN and OFAC sanctions lists).
• Use of the platform to layer, integrate or place funds of unlawful origin.
• Sale of assets the user does not lawfully own or is contractually barred from transferring.
• Structuring transactions to avoid reporting thresholds.
• Use of stolen, synthetic or third-party payment instruments.

6. Record keeping

ReFounder retains transaction records, KYC documentation (held by Stripe), in-platform communications and dispute records for at least five (5) years after the end of the customer relationship, in line with statutory retention requirements.

7. Reporting suspicious activity

Where ReFounder or its payment provider has reasonable grounds to suspect that a transaction is connected to money laundering or terrorist financing, a Suspicious Activity Report (SAR) will be filed with the competent authority without notifying the user (tipping-off prohibition). Funds may be frozen pending investigation.

8. Cooperation with authorities

ReFounder cooperates fully with law-enforcement, tax authorities and financial-supervision bodies in Finland and across the EU, and will share user information when legally required.

9. Reporting concerns

If you suspect that another user is misusing ReFounder for unlawful purposes, please report it through the in-product report button on the relevant listing or profile, or email hello@getrefounder.com.

10. Updates

This policy is reviewed at least annually and updated when material regulatory or operational changes occur.