ANTI-MONEY LAUNDERING POLICY

Financial Integrity, Compliance Control & Anti-Financial Crime Framework

The Shaker Foundation for American Service Heroes maintains a strict institutional commitment to preventing the use of its organization, systems, programs, or affiliated entities for any form of money laundering, terrorist financing, illicit financial activity, or financial misrepresentation.

This Anti-Money Laundering (AML) Policy establishes a comprehensive compliance framework designed to ensure full alignment with internationally recognized financial integrity standards, including global nonprofit compliance principles and financial crime prevention best practices.

The Foundation enforces a zero-tolerance policy toward any activity that may compromise financial transparency or institutional legitimacy.

The Foundation strictly prohibits engagement in or facilitation of the following activities:

3.1 Money Laundering

Any attempt to conceal, disguise, convert, or transfer funds derived from illicit or unauthorized sources.

3.2 Terrorist Financing

Any direct or indirect provision of funds or financial support to individuals or entities involved in unlawful or violent activities.

3.3 Structuring or Evasion Activities

Any attempt to manipulate financial reporting, transaction structuring, or disclosure thresholds to evade monitoring or regulatory review.

3.4 Fraudulent or Misrepresented Funds

Acceptance or processing of funds derived from fraudulent, deceptive, or misrepresented sources.

3.5 Unauthorized Financial Intermediation

Any financial activity conducted outside approved governance, compliance, or authorized institutional channels.

The Foundation implements a risk-based AML compliance system designed to identify, assess, and mitigate financial integrity risks.

Risk categories include:

All transactions and financial interactions are subject to proportional due diligence based on assessed risk level.

The Foundation applies structured due diligence procedures including:

5.1 Identity Verification (KYC Principles)

Verification of identity for relevant stakeholders, partners, and financial counterparts where applicable.

5.2 Source of Funds Assessment

Reasonable verification of the origin and legitimacy of funds associated with institutional activity.

5.3 Beneficial Ownership Awareness

Identification of controlling interests in partner entities where applicable and legally appropriate.

5.4 Enhanced Due Diligence

Applied to high-risk transactions, jurisdictions, or counterparties requiring additional scrutiny.

The Foundation maintains continuous oversight of financial activity through:

Any transaction that raises compliance concerns is subject to immediate review and potential suspension pending verification.

The Foundation maintains comprehensive recordkeeping standards to ensure full audit readiness, including:

All records are retained in accordance with institutional governance and applicable compliance expectations.

AML compliance is supervised by the Foundation’s institutional governance structure, including:

These bodies operate with defined separation of duties to ensure independent verification, enforcement integrity, and accountability.

The AML framework is continuously reviewed and enhanced based on:

The Foundation maintains a permanent commitment to strengthening its anti-financial crime safeguards and governance resilience.

The Shaker Foundation for American Service Heroes affirms that financial integrity is a foundational pillar of institutional credibility.

This Anti-Money Laundering Policy serves as a binding governance instrument designed to ensure that all financial interactions associated with the Foundation are conducted with transparency, accountability, and full compliance with internationally recognized standards of financial integrity.