Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Screening Policy

1. Purpose and place of this document

To prevent money flowing through hangel from being used for laundering the proceeds of crime or financing terrorism. The requested "Sanctions Screening" topic has been included in this text rather than a separate policy, because screening is part of the same money flow. Detailed screening rules for the Association's grant, partner and supplier relationships are in the existing "Counter-Terrorist Financing and Sanctions Screening Policy"; this text covers the money flow on the platform.

2. Scope

• affiliate commissions arriving in hangel's account and transfers to NGOs,
• sponsorship commitments and corporate service income,
• the Association's grant, partner and supplier relationships.

3. Principles

1. A closed and narrow money flow. hangel does not collect money from users; there are no direct cash donations. Money flows only from partner networks and brands into hangel's account, and from hangel's account to the institutional bank accounts of approved NGOs.
2. No cash. Transfers are made only through banks.
3. Known recipients. Money goes only to the bank account declared in the name of an organisation that has been approved by a super-admin.
4. Sanctions lists. No funds or resources are provided to, and no funds are accepted from, persons and entities on the UN Security Council Consolidated List or subject to asset-freezing decisions published in Türkiye under Laws No. 6415 and 7262.
5. Stop when in doubt. When a possible match or suspicious transaction is noticed, the transfer is stopped until it is cleared and the Board of Directors is informed; where needed, a report to the competent authority (MASAK) is considered.
6. Reference framework: Law No. 5549, Laws No. 6415 and 7262 and FATF Recommendation 8 on non-profit organisations.

4. Roles and responsibilities

• Board of Directors: responsible for this policy; designates one of its members as sanctions screening focal point (existing policy).
• Super-admins (finance): record transfers and report unusual amounts and patterns.
• Supervisory Board: checks a sample of screening records during the annual audit (existing policy).

5. How it works at hangel today

• No money is taken from users; the market only redirects to shops.
• Commissions come only from partner networks and brands; conversions reported by the network are compared with platform records every day.
• Transfers to NGOs are made manually at month end by bank transfer to the institutional bank account; a payout record with amount, period and reference is kept for every transfer.
• Organisations' bank details are kept in separate, restricted records.
• No payment is currently collected for sponsorship; only the commitment is recorded.

6. Not yet in place and our goals

• The platform has no step that screens NGOs receiving transfers, or their representatives, against sanctions lists; the manual screening rule of the existing policy also needs to be applied to these NGOs, with records kept.
• There is no monitoring that automatically flags unusual amounts or frequency.
• It is not independently verified that a bank account belongs to the organisation.
• The existing policy states that "organisations on the platform do not receive funds from the Association", whereas transfers to NGOs are made from the Association's account. This statement needs to be updated.

7. How to raise a concern

Suspicious transactions or organisations: kvkk@hangel.org (subject "Whistleblowing — Confidential").

8. Review

At least once a year and whenever sanctions legislation or the money flow changes.

9. Related documents

Existing "Counter-Terrorist Financing and Sanctions Screening Policy" and "AML / CFT Approach Statement" · Donation and Affiliate Transparency Policy · Partnership and Organisational Due Diligence Policy