AML & CFT Policy v. 01

2. Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Policy

This program is designed to align, in good faith and on a risk basis, with the U.S. Bank Secrecy Act (BSA) and FinCEN guidance, EU AML Directives, and Turkish Law No. 5549 and MASAK regulations. This is a voluntary internal control framework adopted by a small proprietorship; it is not a representation that Anya Dahan or the Turkish Company is a regulated financial institution or an "obliged party" under any specific statute. That determination is reserved to the applicable regulator and to counsel, and this Framework will be updated once that legal-capacity analysis is complete.

2.1 Prohibition

Anya Dahan and the Turkish Company categorically prohibit any transaction intended to conceal the origin of illicitly obtained funds, disguise criminal proceeds, or layer funds through art purchases, digital-product sales, or advocacy contributions. No exception is made for high-value or high-profile customers.

2.2 Customer Due Diligence Tiers

This table sets internal review thresholds only. It does not limit or replace the legal reporting duty described in Section 2.4, which applies regardless of transaction size wherever grounds for suspicion exist.

2.3 Suspicious-Activity Indicators

The following are reviewed in context - none is treated as automatically disqualifying, since ordinary explanations (shared household networks, refugee or activist use of VPNs for personal safety, international travel, corporate VPNs) are common and are not themselves evidence of wrongdoing:

• Multiple distinct payment cards used under one name or from one IP address in a short window;
• A billing/card-issuing country that is inconsistent with the stated customer location, without a reasonable explanation;
• Structuring: splitting one payment into several smaller payments to stay under a review threshold;
• A donation or purchase with no plausible relationship to the payer's stated identity or means.

Any restrictive action taken under this section (hold, request for information, decline) is proportionate, documented, and subject to a same-week appeal to the responsible officer, precisely because IP-based and card-based signals can disproportionately affect refugees, activists, and privacy-conscious customers.

2.4 Escalation, Reporting, and the No-Tipping-Off Rule

Where a transaction is flagged as high-risk, the following sequence applies instead of a blanket "payment reversal":

1. Hold the transaction (do not deliver goods or release funds) pending review;
2. Document the basis for suspicion in the internal AML case log;
3. Where the review confirms a plausible legitimate explanation, release the hold and fulfill or refund normally;
4. Where suspicion remains, preserve the transaction and supporting records intact - funds are not returned or moved where doing so could destroy evidence or defeat a legally required freeze - and the matter is escalated to the responsible officer for a decision on filing a Suspicious Transaction Report;
5. Reports are filed with MASAK (Türkiye) and, where applicable, FinCEN (United States), consistent with the principle that a suspicious-transaction report is not conditioned on any minimum amount;
6. Consistent with Turkish Law No. 5549 and equivalent U.S. tipping-off restrictions, the customer is not informed that a report has been filed or that an AML review is underway; where a hold must be explained, only a generic "payment under review" notice is given.

2.5 Segregation of Advocacy and Commercial Funds

• Commercial sales revenue and advocacy contributions are received into separate accounts or, where a single processor account is unavoidable, are tagged and reconciled separately in the bookkeeping records.
• Advocacy contributions are applied only to the specific project or purpose disclosed to the contributor at the time of donation, and a contributor may request a summary of how a contribution over $1,000 was used.

2.6 Record Retention

Transaction records, verification logs, and Suspicious Transaction Report documentation are retained for a minimum of five (5) years from the close of the transaction, consistent with MASAK regulations and U.S. federal audit baselines. Retention of specific data categories (including raw identity-document images) follows the differentiated schedule in Section 4.6, which requires deletion of raw ID scans once verification is complete, ahead of the five-year financial-record retention period, unless a legal hold requires otherwise.