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 collects small, fixed one-time fees (€5–€10) from its registered users and also accepts donations. It does not sell any goods, provides no financial, payment, investment or exchange services, and does not hold, trade or exchange cryptocurrency. All cryptocurrency payments are converted to euros immediately by the regulated payment service provider and paid out to the association's bank account via SEPA.
The association therefore operates a low-risk model that structurally closes the classic pathways of money laundering: there is no way to inject funds into the association and extract them again in another form – as goods, refunds, payouts to third parties, cryptocurrency balances, or converted currency. The flow of funds is strictly one-directional: user fees and donations flow to the association and remain there to finance its statutory activities.
Section 3 – Identification of Users
Payments are accepted only from registered users in order to complete the association's verification procedure. The procedure is operated by the association itself (in-house KYC; no external provider such as Sumsub or IDnow is used) and is documented in detail at wabeo.org/en/verification. Anonymous or pseudonymous use is excluded; 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
The association's treasurer reviews incoming payments and refers anomalies to the responsible contact for closer examination. If, after examination, there are reasonable grounds to suspect money laundering or terrorist financing, this is reported to the competent German authority and the payment service provider in accordance with applicable legal requirements. All payment and verification records are retained for the period required by law and made available to the competent authorities upon lawful request.
Section 6 – Sanctions and Access Restrictions
The observation of German elections is a public activity and is open to any person. Neither German citizenship nor residence in Germany is a legal requirement, and there is no sanctions regime that would require a personal exclusion. The association therefore does not collect information on the citizenship of its users.
Registration on the WABEO platform does, however, require residence in Germany for procedural reasons, because address verification is carried out exclusively via a TAN letter that can only be delivered within Germany.
Where doubts arise in an individual case about a user's identity or the legitimacy of a payment, the service is withheld until the matter has been clarified.
Section 7 – Review
This policy is reviewed at least once a year and updated if the association's activities or the legal requirements change.