Anti-Money Laundering (AML) Policy

Last updated: 7/3/2026

Owambeflow is committed to preventing money laundering, terrorist financing, fraud, and other financial crime. This policy summarises how we apply AML controls to event payments, aso-ebi orders, and E-Spray contributions across the platform.

1. Scope

This policy applies to all event owners, guests, contributors, and any third parties using Owambeflow to send or receive funds. It covers AsoLedger order payments and E-Spray contributions, including contributions made under our anonymity mode.

2. Customer due diligence (CDD)

  • All users must be 18+ and verify their email. Date of birth is captured once and cannot be changed.
  • Event owners may be asked for additional identity verification before payouts above defined thresholds.
  • High-value contributors may be asked to confirm source of funds.

3. Thresholds and enhanced due diligence (EDD)

We apply enhanced checks to single or aggregated transactions that exceed the local equivalent of USD 1,000 within a rolling 30-day window, and to any pattern flagged by our monitoring systems (rapid successive sprays, multiple anonymous contributions to the same event from the same contributor, mismatched geolocations, or sanctioned regions). EDD may include identity verification, proof of address, and source-of-funds documentation.

4. Anonymity in E-Spray

Anonymous mode hides the contributor's identity from the event owner, other guests, and the event chat. It does not anonymise the record internally: Owambeflow retains contributor identity, IP and device data, payment reference, and transaction amount for AML compliance, fraud prevention, and dispute resolution. We will disclose anonymous-contribution identity to regulators, law enforcement, or courts where legally required.

5. Sanctions screening

We screen users and counterparties against applicable sanctions lists (including UN, EU, UK, US OFAC). Matches result in account suspension and reporting where required.

6. Transaction monitoring

We monitor orders, payments, refunds, fulfillment activity, and E-Spray contributions for unusual patterns. Suspicious activity is escalated to our compliance team and may be reported to the relevant Financial Intelligence Unit.

7. Record keeping

AML records — including identity data, transaction history, audit logs, contribution records (anonymous and named), and suspicious activity reports — are retained for at least 5 years from the date of the transaction, or longer where local law requires.

8. Prohibited activity

You may not use Owambeflow to launder funds, finance terrorism, evade sanctions, defraud event guests, collect contributions for unlawful purposes, or split transactions to avoid AML thresholds. Violation results in account termination and reporting to authorities.

9. Reporting

Suspect activity is reported to the appropriate Financial Intelligence Unit. We do not notify customers of suspicious activity reports — "tipping off" is prohibited under most AML regimes.

10. Training and governance

Our staff receive AML training. A nominated compliance officer oversees this programme. The policy is reviewed at least annually and after material changes to the product or applicable regulation.

11. Contact

For compliance enquiries, reach us via the Contact page and mark your message "AML".