# Compliance

As a facilitator of DAF giving and grant payments at scale, Chariot maintains a compliance program designed to meet a high standard of security and regulatory oversight.

Our compliance program focuses on three core areas: **identity verification, gift eligibility, and transaction monitoring**. These processes are managed by our internal compliance team in partnership with trusted external providers.

Sending grant payments to nonprofits carries real risk. It is increasingly easy to falsify documents, impersonate individuals, or misdirect funds.

To address this, Chariot applies multiple layers of verification to ensure that the **right person, with the right authority, at the right organization** is able to receive funds safely.

***

### Identity Verification

**EIN Eligibility**

We conduct a compliance review on an organization’s Employer Identification Number (EIN) to determine whether they have an eligible “Nonprofit Code” and are in “Good Standing” with the IRS.

**Internal Databases**

We have developed a proprietary internal database for organizational eligibility, which includes six different primary data sources that are all updated on a daily or weekly basis:

* IRS Business master File
* IRS 990 Filings
* IRS Publication 78
* OFAC Sanctions

**Additional Documentation**

If an organization does not pass the initial screen, we request additional documentation to evaluate eligibility under common exceptions - such as religious organizations.

***

### Gift Eligibility

Donor Advised Funds (DAFs) have strict rules around when and how donations can be made. Chariot applies multiple layers of controls to ensure that grant recommendations submitted through DAFpay are compliant.

**Organization Eligibility**\
DAFpay is only available to organizations with an EIN that meets DAF eligibility requirements.

**Legal Obligations**\
Our Terms of Service require donors, nonprofits, and fundraising platforms to use DAFpay only for permissible grant activity.

**Quality Assurance**\
Before activation, our team reviews DAFpay implementations to ensure they are used appropriately and not tied to impermissible events.

**Ongoing Monitoring**\
We periodically review DAFpay usage to ensure continued compliance over time.

**DAF Account Requirements**\
DAFpay respects provider-level requirements such as minimum gift amounts, available balances, and user permissions.

**Gift Initiation Transparency**\
Chariot provides DAF partners with additional context on DAFpay donations—such as the webpage where the gift was initiated—to support their due diligence.

{% hint style="info" %}
Chariot does not control a DAF provider’s review and approval process. While our systems support compliance, each provider has final authority over whether a grant is approved based on its own eligibility requirements.
{% endhint %}

***

### Transaction Monitoring

Chariot maintains robust transaction monitoring procedures to ensure oversight of financial activity associated with Chariot Deposit Accounts. We continuously track and analyze transactions for key risk indicators, including:

* Abnormal user behavior
* Potential layering or structuring activity
* Unusual movement of funds
* Large or high-volume transfers

These controls help us identify and address potentially suspicious activity in a timely manner.

{% hint style="info" %}
Transaction monitoring refers to money movement into and out of Chariot Deposit Accounts. It does not apply to DAFpay grant requests, which are governed separately under our Gift Eligibility procedures described above.
{% endhint %}

***

### Key Partners

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#### FS Vector

We utilize FS Vector, the top fintech compliance firm, as compliance counsel. Our engagement has included developing our internal Compliance Program from the ground up, developing all policies and protocols, and ongoing support.
{% endstep %}

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#### Column N.A.

[Column N.A.](https://column.com/) is a nationally chartered bank with an annualized transaction volume exceeding $1 trillion. Other program managers include companies like [Brex](https://www.brex.com/), [Mercury](https://mercury.com/), [Wise](https://wise.com/), and [Bilt.](https://www.biltrewards.com/) Column was built by developers from the ground-up, making it the leading developer bank to power modern, performant experiences.\
\
Other key details on Column include:

* Column maintains a liquid balance sheet to support payments, with over 100% of the Bank’s deposit base available in cash or other immediately available sources of funding.
* Column is more than 2x the “well-capitalized” regulatory threshold.
* Column generates profits from various income streams, resulting in more stable earnings profile across various rate environments.
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