Compliance Agreement for Kiva Withdrawals‏

Discussion in 'Kiva | Loans That Change Lives' started by slickw, Oct 30, 2013.  |  Print Topic

  1. slickw

    slickw Silver Member

    Messages:
    16
    Likes Received:
    11
    Status Points:
    105
    Awhile back I received an email from Kiva asking me to sign a compliance agreement before they would process a withdrawal. They mentioned they do this to comply with anti-money laundering regulations. Is this standard practice with them? Thanks.
     
    tondoleo, milchap and YULtide like this.
  2. milchap
    Original Member

    milchap Gold Member

    Messages:
    27,667
    Likes Received:
    148,061
    Status Points:
    20,020
    Without revealing the amount, can you give us a ballpark figure of the withdrawal?
     
    YULtide and tondoleo like this.
  3. canucklehead
    Original Member

    canucklehead Gold Member

    Messages:
    5,895
    Likes Received:
    22,059
    Status Points:
    11,070
    Yes, Kiva requests this for lenders who make large dollar amount withdrawals (more than $1000) or those who make frequent withdrawals.
     
    YULtide and tondoleo like this.
  4. slickw

    slickw Silver Member

    Messages:
    16
    Likes Received:
    11
    Status Points:
    105
    It's been a few months I don't remember exactly but my PayPal receipt says $1000. The initial email I received was confusing and also based on the spelling and grammatical errors I thought it was a phishing email. I ended up confirming it was legit with Kiva via their main contact email address before responding.
     
    YULtide and milchap like this.
  5. HaveMilesWillTravel
    Original Member

    HaveMilesWillTravel Gold Member

    Messages:
    12,504
    Likes Received:
    20,199
    Status Points:
    16,520
    What information exactly are they asking for in the compliance agreement?

    I am happy to confirm that I won't fund terrorists with *my* money I am withdrawing from *my* Kiva account, but pretty much not much else.
     
    YULtide likes this.
  6. iolaire
    Original Member

    iolaire Gold Member

    Messages:
    3,510
    Likes Received:
    5,767
    Status Points:
    4,170
    + address information

    or see: https://docs.google.com/forms/d/1t2jCvQvBwxNeBAvAzBwmI_4YCHdv4OyxoGMldEjBAds/viewform
     
    YULtide and HaveMilesWillTravel like this.
  7. iolaire
    Original Member

    iolaire Gold Member

    Messages:
    3,510
    Likes Received:
    5,767
    Status Points:
    4,170
    (this I my opinion)
    In this light I recommend shying away from making finical transactions (anywhere, Kiva, Fidelity, PayPal, Bluebird anywhere… ) that appear to serve no purpose or move money around rapidly without a clear goal or benefit. For example don’t start doing things like withdrawing and depositing the same amount of $ from Kiva on the same day. Those types of activities appear questionable and may cause additional scrutiny of your account and in the process result in more overhead costs to Kiva –whom we want to be helping.

    Relating to the “Compliance Agreement for Kiva Withdrawals‏” receiving this doesn’t mean that you were tagged as doing something questionable. It means that you are moving enough money that they need your commitment that you are abiding by the law, and that you understand that they have specific steps that they must take to be in compliance with the law.
     
    YULtide and HaveMilesWillTravel like this.
  8. HaveMilesWillTravel
    Original Member

    HaveMilesWillTravel Gold Member

    Messages:
    12,504
    Likes Received:
    20,199
    Status Points:
    16,520
    Thanks for sharing that. I don't quite understand what submitting that really accomplishes, but I would be okay with providing that information (they should have it anyway from when I signed up or donated money or at least Paypal has it). And the non-US Persons money launderers and terr'ists aren't affected anyway, it seems ;)

    (for the record, I don't make what I consider suspicious transactions through Kiva. I don't churn).
     
    YULtide likes this.
  9. iolaire
    Original Member

    iolaire Gold Member

    Messages:
    3,510
    Likes Received:
    5,767
    Status Points:
    4,170
    (I’m not a legal or financial expert.)
    I think the key part is this:
    I think it accomplishes two things:
    1. You acknowledge that Kiva is complying with these laws, by default I believe that means they are allowed to share data however is needed to comply with those laws, thus you cannot go after them legally for providing your information to a third party in relation to complying with the law
    2. That you state you are in full compliance with the guidelines – likely some legal thing to cover them, so they can say every one of our members who are pulling out $ attested to their honesty…

    Somewhat related conjecture, over the past few years I've seen all my online banks remove ACH transfers for more than $6k in a month. I don't think it’s a trust thing, I think it’s something similar to this, where it’s just easier for them to not allow online transfers above a specific amount. They don’t care if I write check to myself, they just are not going to deal with the legal issues from doing electronic transfers between accounts.
     
    YULtide likes this.
  10. icurhere2
    Original Member

    icurhere2 Gold Member

    Messages:
    21,695
    Likes Received:
    27,682
    Status Points:
    20,020
    And my credit union just put a $6,000 cap on ACH transfers in a 24-hour period.

    You were probably nearby when I spoke to Brandon about this on Saturday (and showed him communications I had with Kiva's Counsel). I was of the belief that the requirement for my "letter" was caused partially by being a "California financial intermediary" instead of federal - I have not moved enough funds in to Kiva over the past 2.5 years to approach the federal threshold.
     
    Last edited: Oct 30, 2013
    iolaire, travelpye and YULtide like this.

Share This Page