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As part of Endaoment’s compliance with sanctions, KYC, and AML regulations, advisors managing client DAF assets must complete a Prohibited Persons/Entities Questionnaire. This questionnaire helps ensure compliance with OFAC sanctions and other regulatory requirements that govern charitable organizations and financial institutions. Complete the questionnaire: Prohibited Persons/Entities Questionnaire For detailed information about our sanctions, KYC, and AML policies, please review our complete compliance framework.

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About the Prohibited Persons/Entities Questionnaire

In order to comply with U.S. regulations prohibiting donor-advised fund (DAF) assets from being invested in any private entity that might confer a prohibited benefit to certain individuals or businesses (referred to as “Disqualified Persons/Entities”), you, as the Donor and/or Primary Advisor, must complete this questionnaire. This process is necessary to ensure compliance with IRS regulations, including IRC §4958, which prohibit any excess benefit transactions.

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Instructions

Please list all Disqualified Persons (DQPs) as defined by law and for the purposes of this DAF investment: The Donor themselves (if an individual) or any individual with advisory privileges on the DAF. The Donor’s entire family, including:
  • Spouse
  • Ancestors
  • Children, grandchildren, and great grandchildren
  • Siblings (including half-siblings)
  • Spouses of children, grandchildren, great grandchildren, and siblings
Please list all 35%-controlled companies where any of the above Disqualified Persons, either alone or collectively, own at least 35% of:
  • The voting interests
  • The profit interests
  • The beneficial interests
If at any time a Disqualified Person (or related entity) changes (e.g., through marriage, divorce, birth, acquisition, disposal of ownership interests, etc.), please provide an updated version of this form to Endaoment to ensure continued compliance. Please ensure that all required fields are completed in full. Incomplete forms could delay the establishment of private market investment capabilities in your DAF. If there are no Disqualified Persons to disclose (other than the Donor themselves), please indicate “None” in each relevant section below.

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Questionnaire FAQ & Additional Guidance

Why do I need to provide this information? Donor-Advised Funds are subject to specific regulations under the Internal Revenue Code. If a DAF invests in a private entity in which a Disqualified Person has a substantial interest, the IRS could deem that an excess benefit transaction, subjecting involved parties to excise taxes and penalties. What if I don’t have complete ownership details for family members? Provide as much information as you have available. If you are unsure, note that in the form and clarify the status. Any missing or incomplete information could delay or limit private investment capabilities. When do I need to update this form? You should update this form annually at minimum if your organization requires annual disclosures, or anytime there is a change that could affect the status of a Disqualified Person or 35%-controlled entity. Who can see this information? This information will be reviewed internally by Endaoment and may be shared with your wealth advisor or other relevant service providers strictly for compliance purposes. It will be handled confidentially in accordance with our privacy policies and any applicable legal requirements. If you have any questions, please reach out to our compliance team at admin@endaoment.org.
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