Sanctions, Know Your Customer (KYC), and Anti-Money Laundering (AML) risk refer to the potential for non-compliance with regulatory requirements, exposure to sanctioned entities or countries, and involvement in illicit financial activities. Given the open nature of the blockchain space and Endaoment’s core values and commitment to compliance, it is essential to establish clear processes for adhering to KYC/AML policies and addressing erroneous or maliciously broadcast blockchain transactions. Effective management of these risks is critical to maintaining our 501(c)(3) status, ensuring regulatory compliance, and upholding the trust of our stakeholders and donors.
Endaoment is committed to providing regulatory-compliant accounts for approved and KYC’d users while preventing any non-compliant activity from sanctioned entities. We manage sanctions, KYC, and AML risks through regular compliance analysis, operational hardness testing, and legal reviews. Our approach includes stringent verification processes, continuous monitoring of transactions, and adherence to practices that prevent involvement with sanctioned individuals or entities. Additionally, we maintain comprehensive incident reporting procedures to ensure timely and effective responses to any compliance breaches or suspicious activities. Compliance with this policy is mandatory for all employees, contractors, board members, and representatives acting on behalf of Endaoment.
Automatically review all transactions in real-time against the current list of Office of Foreign Assets Control (OFAC) sanctioned wallets.
Conduct OFAC screenings for all third parties and potential employees during onboarding and periodically thereafter.
KYC Verification
Endaoment reserves the right to implement KYC procedures for donors as needed, which may include collecting information such as full names and residential addresses for tax and compliance purposes.
For donations at or above $100,000 USD equivalent, Endaoment will apply a level of scrutiny appropriate to the donation amount, conducting any necessary checks to ensure compliance and security, as is deemed necessary by the Board and Executive Team.
Customer due diligence and enhanced due diligence will be conducted at Endaoment’s discretion to verify the identity and authenticity of donors when deemed necessary.
AML Monitoring
Continuously monitor transactions for suspicious activity based on velocity, pattern recognition, and suspect restrictions.
Employ advanced analytics to detect and prevent money laundering activities.
Ensure that critical sanctions, KYC, and AML procedures and systems have segregated duties to prevent any single individual from having full control over any process without oversight.
Approval Processes
Maintain segregated claim diligence and approval processes to uphold checks and balances.