Compliance¶

Guild Role

Responsible for developing Reserve’s policies and procedures to comply with relevant laws, rules, and regulations. It is the policy of Reserve to prohibit and actively prevent money laundering, terrorism financing, and any other illicit activity.

How Reserve is Regulated¶

Reserve’s main development company is regulated as a Money Service Business (“MSB”) by the Financial Crimes Enforcement Network (“FinCEN”). FinCEN is an agency within the United States Department of the Treasury in charge of enforcing the Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) regulations. To comply with these regulations, Reserve’s main development company has implemented a BSA/AML compliance program, which is periodically reviewed and updated to account for changes to regulations and Reserve’s business model.

Compliance Guild¶

The purpose of the Compliance Guild is to ensure that Reserve complies with relevant laws, rules, and regulations by adhering to its written policies and procedures. Two key ways in which the Compliance Guild ensures compliance is by: (1) identifying who customers are at the beginning of the relationship and (2) monitoring their activity throughout the relationship.

• Know Your Customer ("KYC"): focuses on verifying that the user is who they say they are. We collect different information about different people depending on the risk we take by serving them. The risk is often evaluated based on the amount of money being transacted and whether the user is an individual or company.

• Transaction Monitoring: focuses on analyzing user behavior to detect whether Reserve is being used to facilitate illegal activity. We have created processes to identify and flag suspicious or unusual activity for review and to report such activity in a timely manner.

Although compliance guild members are divided between these two teams, everyone is cross-trained and has the knowledge to help out on the other team in case it is overloaded.