Sanctions, KYC, and AML Risk
Abstract
Sanctions/KYC/AML risk refers to the potential for non-compliance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, and the associated exposure to sanctioned entities or countries, including those on OFAC’s SDN list. Given the open nature of the blockchain space, and our core value and commitment to compliance, a clear process for adhering to KYC/AML policies and dealing with erroneous or maliciously broadcast blockchain transactions is essential.
Policy
Endaoment believes in providing regulatory compliant accounts for approved and KYC’d users and preventing any non-compliant activity from sanctioned entities. We manage these risks through regular compliance analysis, operational hardness testing, and legal review.
Scope and Applicability
This policy applied to all Endaoment employees, contractors, board members, and those acting on behalf of Endaoment in any capacity, as well as any accounts created by Endaoment. Non-compliance with this policy may lead to disciplinary action up to and including termination/removal. Should there be a conflict of law, the more stringent of either this policy or the applicable law will be applied.
Operational Controls + Testing
Internal controls will be monitored and/or tested on a periodic basis determined by risk. Monitoring and testing outcomes will be used to inform the continuous improvement of internal controls in order to appropriately mitigate risk.
Training
All Endaoment employees will receive training on Legal Compliance + Regulatory Risk to ensure policy continuity and application. New hires will be trained within their first 60 days, and mandatory incumbent trainings will be conducted bi-annually with all current employees.
Governance
This policy will be reviewed by the executive team and updated semi-annually to ensure it remains up-to-date. Escalation of any questions, concerns, or requests for exceptions regarding this policy must be made to the Endaoment executive team and approved unanimously.