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Financial Crime, Sanctions and Export Controls

Effective

Earlier versions

Money laundering and terrorism financing

  • Cactive Pty Ltd sells software subscriptions. We don’t provide designated services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and we don’t hold, transfer or exchange money or digital currency for customers.
  • Payments go through Stripe, a regulated payment provider, which runs its own identity checks and anti-money laundering controls and screens payments as the laws that apply to it require. Card details go to Stripe, not to us.

Sanctions

  • We don’t knowingly supply services to, or accept payment from, a person or entity sanctioned under Australian law, including the Autonomous Sanctions Act 2011 and the Charter of the United Nations Act 1945, or deal with sanctioned jurisdictions in a way those laws prohibit.
  • Our systems don’t block access by country. We rely on Stripe’s screening of payments, and act on what we learn: if we find an account is held by a sanctioned person, we’ll stop supplying it as the law requires.
  • You must not use Cactive on behalf of a sanctioned person or to get around sanctions.

Export controls

Our apps use standard encryption. Don’t use, export or re-export them in breach of Australian export control laws, including the Defence Trade Controls Act 2012, or the export control laws of other countries that apply to you.

Reporting a concern

If you suspect fraud, money laundering, sanctions evasion or other financial crime involving Cactive, email legal@cactive.com.au. You can report anonymously, and our Whistleblower Policy protects people who speak up.