Anti-Money Laundering & Sanctions Policy

1.1 Applicable Laws and Regulations

Reunion Fund operates in strict compliance with the following US federal laws and international standards:

• Bank Secrecy Act (BSA) - Customer identification, recordkeeping, and reporting requirements
• USA PATRIOT Act - Enhanced due diligence and customer identification procedures
• Anti-Money Laundering Act of 2020 - Beneficial ownership identification and reporting
• Office of Foreign Assets Control (OFAC) - Sanctions screening and compliance
• Financial Crimes Enforcement Network (FinCEN) - Suspicious Activity Reporting (SAR) requirements
• Financial Action Task Force (FATF) - International anti-money laundering standards
• State money transmitter licensing - Where applicable to our operations

1.2 Policy Scope

This policy applies to:

• All Reunion Fund employees, officers, directors, and contractors
• All customers and users of the Reunion Fund platform
• All financial transactions processed through our platform
• All third-party payment processors and financial service providers
• All business relationships and partnerships

2.1 Customer Identification Program (CIP)

All customers must provide the following information before using our platform:

• Individual Customers: Full legal name, date of birth, residential address, and government-issued identification number (SSN or ITIN)
• Business Customers: Legal business name, business address, Employer Identification Number (EIN), and beneficial ownership information
• Verification: Documentary verification of identity through government-issued photo identification
• Address Verification: Utility bills, bank statements, or other reliable sources not more than 90 days old

2.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is required for the following high-risk scenarios:

• Customers from high-risk geographic locations as defined by FATF
• Politically Exposed Persons (PEPs) and their family members or close associates
• Customers involved in high-risk businesses or industries
• Transactions exceeding $10,000 in a single day
• Unusual or suspicious transaction patterns
• Customers with negative media or adverse information

EDD procedures include:

• Source of funds verification
• Additional documentation requirements
• Senior management approval for account opening
• Enhanced ongoing monitoring
• Periodic review and update of customer information

2.3 Beneficial Ownership Identification

For all business customers, we identify and verify beneficial owners who:

• Own, directly or indirectly, 25% or more of the equity interests
• Exercise significant control over the business entity
• Are designated as the controlling person if no individual meets the ownership threshold

3.1 OFAC Sanctions Lists

Reunion Fund maintains real-time screening against all OFAC sanctions lists, including:

• Specially Designated Nationals and Blocked Persons List (SDN)
• Sectoral Sanctions Identifications List (SSI)
• Foreign Sanctions Evaders List (FSE)
• Non-SDN Palestinian Legislative Council List
• All country-specific and program-specific sanctions lists

3.2 Screening Procedures

Our sanctions screening program includes:

• Pre-boarding: All new customers screened before account activation
• Real-time: All transactions screened at point of initiation
• Ongoing: Daily batch screening of all customer records
• Updates: OFAC list updates processed within 4 hours of publication
• Geographic: Screening for sanctioned countries and regions

3.3 Match Investigation and Resolution

When potential sanctions matches are identified:

• Transactions are immediately blocked pending investigation
• Senior compliance officer reviews all match details within 2 hours
• False positives are cleared and documented
• True matches result in account blocking and OFAC reporting
• All investigations are documented and retained for 5 years

4.1 Automated Monitoring Systems

Our transaction monitoring system identifies potentially suspicious activities including:

• Transactions inconsistent with customer profile or business model
• Unusual transaction amounts, frequency, or timing
• Structuring activities designed to avoid reporting thresholds
• Rapid movement of funds without apparent business purpose
• Transactions involving high-risk geographic locations
• Campaigns with suspicious fundraising patterns or purposes

4.2 Monitoring Thresholds and Parameters

4.3 Manual Review Process

All alerts generated by automated systems undergo manual review:

• Initial review completed within 24 hours of alert generation
• Investigation includes customer profile analysis and transaction history
• External database searches for adverse media or regulatory actions
• Senior compliance officer approval for alert disposition
• Escalation to law enforcement when warranted

5.1 SAR Filing Requirements

Reunion Fund files Suspicious Activity Reports (SARs) with FinCEN for:

• Known or suspected criminal violations aggregating $5,000 or more
• Suspected criminal violations aggregating $25,000 or more regardless of potential suspect identification
• Transactions lacking apparent lawful purpose and aggregating $5,000 or more
• Attempted structuring of transactions to evade reporting requirements
• Any transaction suspected of financing terrorism regardless of amount

5.2 SAR Filing Timeline

Our SAR filing procedures ensure timely compliance:

• Initial Detection: Suspicious activity identified through monitoring systems or manual review
• Investigation: Completed within 30 calendar days of initial detection
• Filing: SAR filed within 30 calendar days of initial detection
• Extension: Additional 30 days permitted if no subject identified
• Continuing Activity: Follow-up SARs filed every 90 days if activity continues

5.3 Confidentiality Requirements

SAR information is strictly confidential and protected:

• No disclosure of SAR filing to subjects or unauthorized parties
• Limited access to SAR information on need-to-know basis
• Secure storage and handling of all SAR documentation
• Regular training on confidentiality requirements

6.1 Required Records

Reunion Fund maintains comprehensive records including:

• Customer identification records: Original identification documents and verification records
• Transaction records: All payment instructions, confirmations, and supporting documentation
• Monitoring records: Transaction monitoring alerts, investigations, and dispositions
• Training records: Employee AML training completion and certification
• Compliance records: Policy reviews, audits, and regulatory correspondence

6.2 Retention Periods

6.3 Data Security and Access Controls

All records are protected through:

• Encryption of sensitive data at rest and in transit
• Role-based access controls limiting access to authorized personnel
• Regular backup and disaster recovery procedures
• Audit trails for all record access and modifications
• Secure destruction of records at end of retention period

7.1 AML Officer Designation

Reunion Fund has designated a qualified AML Compliance Officer responsible for:

• Overall AML program implementation and oversight
• Ensuring compliance with all applicable laws and regulations
• Coordinating with law enforcement and regulatory agencies
• Conducting risk assessments and program effectiveness reviews
• Reporting to senior management and board of directors

7.2 Employee Training Requirements

All employees receive comprehensive AML training including:

• Initial training: Completed within 30 days of hire
• Annual training: Updated training completed yearly
• Role-specific training: Additional training for compliance and customer-facing roles
• Regulatory updates: Training on new regulations and requirements
• Red flag identification: Recognition of suspicious activities and reporting procedures

7.3 Independent Testing and Audit

AML program effectiveness is assessed through:

• Annual independent testing by qualified third parties
• Risk-based internal audits of AML procedures
• Regulatory examination preparation and response
• Corrective action plans for identified deficiencies
• Board and senior management reporting on program effectiveness

8.1 Risk Assessment Framework

Reunion Fund conducts comprehensive risk assessments considering:

• Customer risk: Geographic location, business type, transaction patterns
• Product risk: Peer-to-peer fundraising, milestone-based releases, cryptocurrency options
• Geographic risk: Countries with higher money laundering or terrorist financing risk
• Distribution risk: Online platform delivery channels and third-party relationships

8.2 High-Risk Categories

Enhanced monitoring applies to:

• Campaigns involving international beneficiaries
• Large-value fundraising campaigns (exceeding $100,000)
• Cryptocurrency payment options
• Customers from FATF high-risk jurisdictions
• Politically exposed persons and their associates
• Non-profit organizations in high-risk regions

9.1 Currency Transaction Reports (CTRs)

CTRs are filed for:

• Currency transactions exceeding $10,000 in a single business day
• Multiple currency transactions that aggregate to more than $10,000
• Filed within 15 days of the transaction date

9.2 OFAC Blocking Reports

When assets are blocked due to OFAC sanctions:

• Initial blocking report filed within 10 business days
• Annual reports for blocked assets filed by September 30
• Immediate notification to OFAC for urgent situations

10.1 Employee Violations

Violations of this AML policy may result in:

• Immediate suspension pending investigation
• Disciplinary action up to and including termination
• Referral to law enforcement agencies
• Civil and criminal liability under applicable laws

10.2 Customer Violations

Customer violations may result in:

• Immediate account suspension or termination
• Transaction blocking and fund holds
• SAR filing with FinCEN
• Law enforcement referral
• Cooperation with regulatory investigations

11.1 AML Compliance Officer

11.2 Reporting Suspicious Activity

To report suspected money laundering or suspicious activity:

• Email: aml-reports@reunionfund.com
• Phone: 24/7 compliance hotline available
• Secure online portal for confidential reporting
• Anonymous reporting options available