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Update compliance.mdx
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Hyperlink to latest compliance program
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salo1serfati committed Jan 16, 2025
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Expand Up @@ -6,72 +6,4 @@ createdAt: "Sun May 21 2023 20:36:07 GMT+0000 (Coordinated Universal Time)"
updatedAt: "Wed May 01 2024 21:30:05 GMT+0000 (Coordinated Universal Time)"
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Chariot maintains a thorough compliance program that surpasses both industry standards and Chariot’s partner banks.

## BSA/AML Compliance

Chariot is building a robust BSA/AML compliance program to detect and prevent any nonprofits involved in money laundering and terrorist financing.

This includes:

1. Dedicated Chief Compliance Officer and BSA/AML Officer responsible for implementing, managing, and overseeing the program, supported by FS Vector Advisory services.
2. Customer Identification Program (CIP) to verify the identity of all nonprofit clients and their beneficial owners.
3. Risk-based customer due diligence (CDD) and enhanced due diligence (EDD), as needed, based on nonprofit type, geographic location, transaction activity, and other risk factors.
4. Ongoing transaction monitoring to identify suspicious activity.
5. Screening of nonprofits and associated individuals against OFAC and other government sanctions lists.
6. Policies, procedures and controls to ensure compliance with the Patriot Act, Bank Secrecy Act, and other applicable AML laws and regulations.

## Nonprofit Compliance

Chariot conducts comprehensive due diligence on the nonprofit, including:

1. Verifying the nonprofit's good standing with the IRS and state authorities.
2. Reviewing the nonprofit's IRS Form 990 (if applicable) and IRS Publication 78 status.
3. Screening the nonprofit and its principals against OFAC sanctions lists.
4. Assessing the nonprofit's reputation and evaluating its charitable programs and governance.
5. Confirming the intended use of funds aligns with legitimate nonprofit purposes.

These additional controls provide further assurance that funds will be used appropriately by the recipient nonprofits.

## Fraud Prevention

To mitigate fraud risk, Chariot will implement:

1. Fraud detection tools to prevent unauthorized transactions.
2. Dual control and secondary approval for high-risk transactions.
3. Employee training on identifying potential nonprofit fraud red flags.
4. Policies requiring nonprofits to provide detailed support for large or unusual transactions.

## Account Use Restrictions

Chariot will ensure that nonprofits attest to the use of funds being used for charitable purposes as required by the IRS.

Prohibited transactions and activities include:

1. Processing payments for goods or services unrelated to legitimate nonprofit purposes.
2. Allowing the account to be used by an entity other than the approved nonprofit.

<Warning>
Caution: Grantmakers must ensure that donors confirm the grant provides no private benefit, does not satisfy any existing obligations, and complies with all applicable IRS guidelines
</Warning>

## Information Security

To safeguard sensitive nonprofit and donor PII and financial data, Chariot adheres to stringent information security standards, including:

1. Encryption of data in transit and at rest.
2. Secure storage of data in SOC 2 Type 2-certified cloud environments.
3. Role-based access controls and audit logging.
4. Annual penetration testing and vulnerability assessments.
5. Employee security awareness training.
6. Incident response plan to promptly investigate and remediate any suspected breaches.

## Vendor Management

Chariot maintains a third-party risk management program to assess and monitor vendors, which includes:

1. Thorough due diligence before engaging new vendors.
2. Risk assessments and ongoing monitoring of vendor security and performance.
3. Contracts with vendors incorporating security requirements and audit rights.
4. Annual vendor risk assessments and reviews.
5. Vendor employee training and background checks as applicable.
Chariot - as a fintech company sending payments nonprofits and partnering with an OCC-regulated bank - adheres to stringent nonprofit eligibility and banking compliance standards. An overview of this program [can be viewed here](https://docs.google.com/document/d/1nQngEIDJKhHyKig-SO5PObvlAvDahHX0lv95ESIMn-Q/edit?usp=sharing)

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