Policy for the Prevention of Money Laundering and Terrorist Financing
Adopted by the board on 20 July 2026.
Responsible contact: Stephanie Tsomakaeva, Secretary General
Email: schatzmeister@buerger-fuer-deutschland.org.
Section 1 – Purpose and Scope
This policy sets out how Bürger für Deutschland e. V. ("the association") prevents its services from being misused for money laundering or terrorist financing. It applies to all payments received through the platform my.wabeo.org, including payments made in cryptocurrency.
Section 2 – Risk Assessment
The association operates a low-risk model: it collects only small, fixed one-time fees (€5–€10) from its own registered users. It does not sell physical goods, provides no financial or investment services, and does not hold, trade or exchange cryptocurrency. All cryptocurrency payments are converted to euros immediately by a regulated payment service provider and paid out to the association's bank account via SEPA.
Section 3 – Identification of Payers
Payments are accepted only from registered users who have provided a verified name, a verified address and a confirmed email address. Anonymous payments are not possible. The association does not accept payments on behalf of third parties and does not make payouts to third parties.
Section 4 – No Custody of Cryptocurrency
The association never holds cryptocurrency at any time. Conversion to euros and payout are handled entirely by the regulated payment service provider. Only euro amounts appear in the association's records.
Section 5 – Monitoring of Payments
Because the fees are fixed and low, any deviation is easy to notice. The association's treasurer reviews incoming payments and refers anomalies to the responsible contact for closer examination. Anomalies include in particular unusually large or repeated payments, attempts to split or structure payments, and the abuse of refunds.
Section 6 – Sanctions and Higher-Risk Persons
The association knowingly provides no services to persons subject to applicable financial sanctions. Its users are individual volunteers. Where doubts arise about a user's identity or the legitimacy of a payment, the service is withheld until the matter has been clarified.
Section 7 – Reporting of Suspicious Cases
If, after examination, there are reasonable grounds to suspect money laundering or terrorist financing, the responsible contact reports this to the competent German authority (Financial Intelligence Unit, FIU) in accordance with applicable legal requirements and cooperates with the payment service provider.
Section 8 – Record Keeping
Payment and verification records are retained for the period required by law and made available to the competent authorities upon lawful request.
Section 9 – Review
This policy is reviewed at least once a year and updated if the association's activities or the legal requirements change.