Hartman and Benz, Inc., a Delaware Corporation (the “Company”), is committed to prohibiting and actively preventing money laundering, terrorist financing, and related financial crimes. The Company ensures compliance with the U.S. Bank Secrecy Act (BSA), the USA PATRIOT Act, Securities and Exchange Commission (SEC) rules, Financial Industry Regulatory Authority (FINRA) requirements, and other applicable laws and regulations. This policy sets forth the framework of the Company’s AML and KYC procedures in connection with its share offering and related investor activities.
Definition of Money Laundering and Terrorist Financing
Money laundering refers to processes intended to conceal the origins of funds derived from illegal activity, so that the funds appear legitimate. This generally involves three stages:
Placement – introduction of illicit funds into the financial system.
Layering – transferring or moving funds to obscure their origins.
Integration – reintroducing laundered funds into the economy as seemingly legitimate assets.
Terrorist financing may involve both legitimate and illegitimate funds but shares the goal of concealing sources and intended uses. Transactions can be small and simple, but still pose significant risks to the integrity of financial systems.
Policy Commitment
The Company maintains written AML and KYC policies, procedures, and internal controls designed to ensure full compliance with all relevant requirements. These policies are subject to ongoing review and updates to account for changes in regulation, enforcement priorities, or the Company’s business operations. A Chief Compliance Officer (CCO) is designated to oversee implementation, training, and enforcement.
Investor Identification
Before permitting any subscription for Shares, the Company must establish the identity of each investor beyond a reasonable doubt. Required documents include government-issued identification and proof of address. To prevent misuse of documents, investors may also be asked to provide a live image, video verification, or other biometric proof to confirm their likeness. If identity cannot be adequately verified, the Company will not accept the subscription.
Entity Verification
For corporate or institutional investors, enhanced verification is conducted. This includes review of formation documents, shareholder and beneficial ownership records, board resolutions, and verification of authorized representatives. The Company must determine ultimate beneficial ownership and confirm the nature of the entity’s business before accepting any investment.
Transaction Monitoring
All transactions related to the subscription and transfer of Shares are subject to monitoring. The Company employs both automated systems and manual review by AML specialists to detect unusual or suspicious activity. Red-flagged transactions may require additional verification, temporary suspension, or filing of reports with regulatory authorities.
Enhanced Due Diligence
Where investors present heightened risk — such as Politically Exposed Persons (PEPs), investors from high-risk jurisdictions, or those with complex ownership structures — the Company will apply enhanced due diligence. This includes greater scrutiny of the investor’s source of funds, ongoing monitoring, and possible restrictions or rejection of the subscription.
Prohibited Practices and Restrictions
The Company does not accept:
- Cash deposits or withdrawals.
- Investments through third parties or nominee accounts without prior approval.
- Anonymous or incomplete documentation.
The Company reserves the right to reject any investment in Shares where AML/CTF concerns exist. The Company is also legally prohibited from notifying investors if their activity has been reported to authorities.
Sanctions Screening
The Company conducts ongoing screening against U.S. and international sanctions lists, including those maintained by the Office of Foreign Assets Control (OFAC), the United Nations, and other global regulators. Any investor appearing on a sanctions list will be denied participation in the share offering.
KYC Verification Levels
Depending on the size and nature of an investment, the Company applies tiered verification requirements:
- Level 1: Government-issued ID and address verification for basic investments.
- Level 2: Proof of residence, such as a utility bill or bank statement, for medium-sized investments.
- Level 3: Verification of source of funds and wealth, along with video verification, for significant investments or higher-risk investors.
These requirements may be updated as laws evolve or as determined necessary by the Compliance Officer.
Reporting and Cooperation with Authorities
The Company may file Suspicious Activity Reports (SARs) or other required filings with the Financial Crimes Enforcement Network (FinCEN), SEC, or other authorities as applicable. The Company will cooperate fully with law enforcement and regulators, and all filings are confidential.