Anti-Fraud Policy
Effective Date: [EFFECTIVE DATE] Last Updated: [LAST UPDATED] Version: 2.0
1. Purpose
KidStarter is committed to preventing, detecting, and responding to fraud to protect Donors, Students, Organizations, and the integrity of the Service. This Policy forms part of the Agreement (see Terms of Service).
2. Fraud Prevention Controls
KidStarter implements multiple fraud prevention controls:
| Control | Description |
|---|---|
| Creator Verification | Identity verification, authority confirmation, documentation review (see Verification Policy) |
| Organization Verification | Institutional legitimacy checks, domain verification, registration document review |
| Campaign Review | Pre-publication and ongoing review of Campaign content and documentation |
| Transaction Monitoring | Real-time and periodic analysis of donation patterns, velocity, amounts, and anomalies |
| Device and IP Signals | Device fingerprinting, IP geolocation, behavioral analysis to detect suspicious activity |
| Sanctions and Screening | Sanctions list screening, PEP checks, and adverse media screening (see KYC/KYB Notice) |
| Payment Processor Controls | Leveraging processor fraud tools (e.g., Stripe Radar) for transaction-level risk scoring |
| Documentation Cross-Checks | Comparing submitted documentation (invoices, authorization letters) against independent sources |
| User Reports | Community-powered fraud detection through reporting channels |
3. Fraud Detection Indicators
KidStarter monitors for indicators including but not limited to:
- Multiple Campaigns with similar narratives from different accounts;
- Rapid creation of multiple Campaigns;
- Unusual donation patterns (high frequency, identical amounts, unusual hours);
- Donations from high-risk jurisdictions without legitimate connection to the Campaign;
- Forged or altered documentation;
- Mismatches between Creator credentials and Campaign details;
- Requests for disbursement changes (e.g., new vendor, different school) without clear justification;
- Chargeback patterns;
- Device/IP shared across unrelated accounts.
4. Enforcement
When fraud is suspected or confirmed, KidStarter may take one or more of the following actions:
4.1. Immediate Actions:
- Pause or remove the Campaign;
- Freeze pending disbursements;
- Suspend the User's account;
- Block the payment method.
4.2. Investigation:
- Request additional documentation from the Creator, Organization, or Donor;
- Conduct internal investigation (document review, cross-referencing, interviews);
- Engage third-party fraud investigation services where appropriate.
4.3. Resolution:
- Reverse transactions where feasible and funds remain available;
- Process refunds to affected Donors;
- Permanently ban the User;
- Recover disbursed funds where possible (clawback).
4.4. External Reporting:
- Report to payment processors (Stripe, card networks);
- File Suspicious Activity Reports (SARs) with applicable Financial Intelligence Units where required or appropriate (e.g., FinCEN in the US, NCA in the UK, FINTRAC in Canada, national FIUs in the EU);
- Report to law enforcement;
- Report to regulatory authorities;
- Cooperate with legal proceedings.
5. Cooperation with Law Enforcement
5.1. KidStarter cooperates with law enforcement investigations in all jurisdictions where it operates, in accordance with applicable law.
5.2. We may disclose information to law enforcement agencies where required by law, in response to valid legal process (subpoena, court order, search warrant), or where we have a good-faith belief that disclosure is necessary to prevent fraud, protect the safety of individuals, or enforce our policies.
5.3. We preserve relevant data and evidence for law enforcement in accordance with legal hold procedures and applicable data retention laws.
6. Whistleblower Protections
6.1. KidStarter encourages all Users, employees, contractors, and partners to report suspected fraud in good faith.
6.2. No Retaliation: KidStarter will not retaliate against any individual who reports suspected fraud in good faith. This includes protection from account suspension, termination of employment, or any other adverse action taken as a consequence of making a report.
6.3. Reports may be made anonymously through [REPORT LINK OR EMAIL] or, for employees, through KidStarter's internal whistleblower channel.
6.4. KidStarter complies with applicable whistleblower protection laws, including the EU Whistleblower Directive (2019/1937), the UK Public Interest Disclosure Act 1998, and applicable US and Canadian federal and state/provincial whistleblower protections.
7. User Responsibilities
7.1. Users are responsible for: providing truthful information; not submitting false documentation; not attempting to manipulate the Service; and reporting suspected fraud.
7.2. Participation in, facilitation of, or failure to report known fraud may result in account suspension, permanent ban, and referral to law enforcement.
8. Record Retention
KidStarter retains fraud investigation records, evidence, and outcomes for a minimum of 7 years or longer where required by law, in accordance with the Data Retention & Deletion Policy.
9. Contact
Report Fraud: [REPORT LINK OR EMAIL] General Support: [SUPPORT EMAIL]