PTAnti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy
1. Purpose
This Policy summarizes the principles and controls Frendz adopts to prevent the platform from being used for money laundering, terrorist financing or the financing of the proliferation of weapons of mass destruction.
2. Who we are and how payments work
Frendz is a technology platform for creators and companies that sell digital products (courses, memberships and digital content) in Brazil and abroad. Payment processing, custody of funds and settlement are performed by partner acquirers and payment institutions licensed and supervised by the Central Bank of Brazil. International sales are received by Frendz LLC, a related company in the United States, and processed by licensed partners.
Frendz is not an institution authorized by the Central Bank and keeps this program on a voluntary basis, aligned with Lei nº 9.613/1998 (anti-money laundering law), Lei nº 13.260/2016 (anti-terrorism law), Lei nº 13.810/2019 (UN Security Council sanctions) and Lei nº 13.709/2018 (LGPD, the Brazilian data protection law). Reports to COAF (the Brazilian financial intelligence unit) are filed by the partner institutions; Frendz reports suspicious cases to them and cooperates with authorities upon lawful request.
3. Governance
The Policy is approved by management. The AML/CFT program is led by a managing partner of Frendz, who conducts the reviews, decides the measures in risk cases, organizes training and reviews the program every six months.
4. Seller identification (Know Your Customer)
No producer, co-producer or affiliate can sell or withdraw before their registration is approved. To do so, Frendz:
- checks the CPF or CNPJ with the Brazilian Federal Revenue (companies must be active, with the legal representative identified);
- verifies the identity document with liveness detection and face matching;
- screens against national and international sanctions lists (including UN, OFAC and the European Union) and politically exposed person (PEP) lists;
- requires the payout account to belong to the same CPF or CNPJ as the seller;
- records acceptance of the terms and the PEP self-declaration;
- identifies the ultimate beneficial owners of legal entities when the ownership structure requires it.
5. Enhanced due diligence
Higher-risk cases go through enhanced review before proceeding: PEPs, companies with complex ownership, foreign sellers, inconsistent data, unusual volume and high dispute, MED, chargeback or refund rates. The review may include additional documents, evidence of the activity and of the origin of funds, temporary balance holds, lower limits, manual approval of products or termination of the relationship.
6. Monitoring and limits
Transactions are monitored continuously on a risk basis. Withdrawals go only to the seller's own verified account and are limited to the available balance. Transfers to third parties are disabled by default and are enabled, with limits, only after review. Balances linked to open disputes are held until they are resolved.
7. What we do not accept
We do not accept anonymous accounts, shell companies, sanctioned persons or entities, or products prohibited by our Content Policy or by law.
8. Confidentiality, records and data protection
AML/CFT reviews are confidential, and the person involved is not informed of suspicious activity reports. Identification and transaction records are kept for the legal retention periods. Personal data is processed in accordance with the LGPD and our Privacy Policy.
9. Training and review
The team receives AML/CFT training every six months. The program is reviewed internally every six months, or earlier when there is a relevant change in law, business or partners.
10. Reporting channel
To report suspected money laundering, fraud, prohibited products or any irregularity, write to denuncia@frendz.com.br. General support: sac@frendz.com.br.