Child Sexual Abuse and Exploitation Policy (CSAE)

CSAE Policy

Child Sexual Abuse and Exploitation Policy (CSAE)

CSAE Policy

1. Purpose and Scope

LaunchGood (hereinafter referred to as "the Platform") is dedicated to fostering a safe and responsible platform that upholds ethical standards and protects vulnerable populations, particularly children. This policy is designed to prevent, detect, and mitigate risks associated with child sexual abuse and exploitation (CSAE) in alignment with regulatory requirements in the U.S., Canada, and the U.K. It applies to all platform users, employees, and third-party partners engaged with LaunchGood's services.

• The Platform is committed to preventing child sexual abuse and exploitation (CSAE) on its platform.
• This policy outlines our approach to identifying, reporting, and preventing CSAE activities in compliance with regulatory requirements in the U.S., Canada, and the U.K., including the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), the Office of the Superintendent of Financial Institutions (OSFI), the U.S. Financial Crimes Enforcement Network (FinCEN), the National Center for Missing & Exploited Children (NCMEC), the Department of Justice (DOJ), the U.K.'s Financial Conduct Authority (FCA), the National Crime Agency (NCA), and the Internet Watch Foundation (IWF).

2. Regulatory Framework

Ensuring compliance with all relevant regulatory frameworks is critical in combating CSAE. This policy aligns with key regulations and laws in the U.S., Canada, and the U.K., providing a legal foundation for enforcement and reporting.

• U.S.: The Protect Our Children Act, the Trafficking Victims Protection Act (TVPA), the Bank Secrecy Act (BSA), FinCEN's Advisory on Human Trafficking and Child Exploitation, and reporting obligations to NCMEC and DOJ.
• Canada: The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC's Indicators of Suspicious Transactions for Human Trafficking, the Criminal Code (child exploitation offenses), and OSFI's compliance standards.
• U.K.: The Children Act 1989 & 2004, the Sexual Offences Act 2003, the Online Safety Act 2023, the Modern Slavery Act 2015, FCA's guidance on financial crime, NCA's reporting obligations for CSAE, and IWF's role in monitoring online CSAE content.

3. Prohibited Activities

The Platform maintains a strict zero-tolerance policy for CSAE-related activities. Users, organizations, or campaigns found engaging in such activities will face immediate action.

• Child pornography, abuse, or exploitation
• Trafficking of minors
• Online grooming and predatory behaviors
• Any activity that enables CSAE

4. Due Diligence and Risk-Based Approach

The Platform implements a robust risk-based approach to ensure proactive prevention, monitoring, and intervention against CSAE-related activities. This approach includes thorough risk assessments and enhanced compliance measures.

• Enhanced Due Diligence (EDD): High-risk users and fundraisers undergo additional scrutiny, including identity verification and background screening.
• Know Your Customer (KYC) & Know Your Business (KYB): Verification of all fundraisers, including documentary evidence, source of funds, and intended use.
• Ongoing Monitoring: Continuous transaction and behavioral analysis using AI-driven monitoring systems to detect suspicious patterns.

5. Reporting Obligations

Reporting CSAE-related activities is a legal and ethical obligation. The Platform ensures timely and accurate reporting to relevant authorities to facilitate prompt investigations and interventions.

• Mandatory Reporting: Suspicious activity related to CSAE is reported to FINTRAC (Canada), FinCEN (U.S.), NCA (U.K.), and NCMEC.
• SAR/STR Filings: If a transaction or user is suspected of involvement in CSAE, a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) will be filed with the relevant authorities.
• Collaboration with Law Enforcement: The Platform fully cooperates with law enforcement agencies in investigations concerning CSAE.

Reportable Offenses and Reporting Authorities

The following table outlines the types of offenses that constitute a reportable CSAE activity and the appropriate authorities to which they must be reported.

Reportable Offense	Reporting Authority
Child pornography production/distribution	NCMEC (U.S.), NCA (U.K.), FINTRAC (Canada)
Online grooming or solicitation	DOJ (U.S.), NCA (U.K.), FINTRAC (Canada)
Human trafficking of minors	FinCEN (U.S.), OSFI (Canada), FCA (U.K.)
Fundraising for CSAE-related activities	FINTRAC (Canada), FinCEN (U.S.), FCA (U.K.)
Financial transactions linked to CSAE	FINTRAC (Canada), FinCEN (U.S.), NCA (U.K.)

The Platform is committed to ensuring that any suspected CSAE activity is promptly reported to the appropriate authorities, protecting victims, and preventing further harm.

6. Content Moderation and Platform Security

To safeguard against CSAE-related content and transactions, The Platform employs advanced moderation technologies and proactive security measures.

• Automated detection tools for CSAE-related content
• AI-based scanning of images and text for known exploitative material
• User reporting mechanisms to flag suspicious content or activity
• Collaboration with global child protection organizations to identify and remove CSAE content

7. Staff Training and Awareness

A well-trained team is essential in identifying and preventing CSAE risks. The Platform prioritizes ongoing education and training to ensure employees are equipped to handle CSAE-related concerns effectively.

• Mandatory training on CSAE risk indicators for all compliance, trust & safety, and customer support teams.
• Regular updates to training based on regulatory guidance and emerging threats.
• Partnership with child protection agencies to develop training content tailored to emerging threats and typologies.

8. Record-Keeping and Compliance Reviews

Accurate documentation and regular audits enhance compliance and accountability. The Platform ensures meticulous record-keeping of all CSAE-related reports and actions taken.

• All CSAE-related reports, investigations, and regulatory filings are retained for a minimum of five years.
• Annual internal audits and independent reviews of the platform's CSAE risk management framework.
• Regular assessments of monitoring systems to improve effectiveness in detecting CSAE-related activities.

9. Enforcement and Disciplinary Actions

The Platform enforces strict disciplinary actions against users, organizations, or employees found in violation of this policy. These actions are designed to deter CSAE and maintain the integrity of the platform.

• Immediate account suspension and fund freezing for suspected CSAE-related activities.
• Permanent bans and legal action against users violating this policy.
• Escalation of confirmed cases to relevant regulatory and law enforcement agencies.
• Termination of partnerships with third parties found to be non-compliant with CSAE policies.

10. Policy Review and Updates

To adapt to evolving regulatory requirements and emerging threats, The Platform periodically reviews and updates this policy. Any changes will be communicated to stakeholders accordingly.

• This policy is reviewed annually to ensure compliance with evolving regulatory requirements and best practices in CSAE prevention.
• Independent external reviews will be conducted to assess and enhance the effectiveness of the policy.