What We Do — and Why It Matters
We operate a closed-loop civic rewards platform. Community Credits are earned through verified civic actions — visiting local markets, supporting vendors, and participating in community programs. They cannot be purchased with cash, transferred between users, or converted back to fiat currency.
This structural architecture is our primary defense against financial crime. The policies below document how we maintain that integrity and respond when something unusual appears.
Risk-Based Customer Due Diligence
We understand who uses our platform, why, and how their activity patterns read over time.
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Know the purpose of the relationship.
At account creation, we collect basic identity information and the stated reason for using the platform (patron, vendor, sponsor, or corporate partner). We verify vendor and sponsor accounts before they are granted pool funding access.
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Assign and maintain customer risk profiles.
Each account carries an internal risk score based on transaction volume, redemption patterns, and behavioral signals. Accounts with patterns inconsistent with their stated purpose are flagged for review.
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Conduct ongoing monitoring.
We monitor accounts continuously for unusual activity — including abnormal redemption frequency, rapid credit accumulation, or activity patterns that suggest coordinated structuring across accounts.
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Keep customer information current.
We prompt users to confirm or update their account details on an annual basis. Dormant accounts are reviewed before reactivation. Vendor and sponsor accounts are re-verified whenever their payout or pool configuration changes.
Designed to Prevent Illicit Finance
Our platform's architecture is its primary AML defense. The following structural constraints are hardcoded and non-negotiable.
🔒 No Patron Cash On-Ramp
Community Credits cannot be purchased with cash or card by patrons. They are earned exclusively through verified civic actions, eliminating the classic cash injection (smurfing) entry point.
🔒 No Patron Fiat Off-Ramp
Credits can only be redeemed for predefined goods and services within the platform. There is no mechanism to convert Community Credits to USD, ACH transfers, or any external financial instrument.
🔒 Soulbound Tokens
Credits earned by one patron cannot be transferred to another patron. This is enforced at the database level with a trigger that rejects any patron-to-patron transaction.
🔒 Daily Balance Cap
No patron wallet may accumulate more than the equivalent of $2,000 USD in Community Credits within a rolling 24-hour window. This cap is enforced algorithmically before any credit is issued.
🔒 Pre-Funded Escrow Only
All capital entering the platform's liquidity pools arrives through verified corporate vendors, sponsors, or grant institutions. No Community Credits are minted unless the corresponding USD value is pre-deposited and verified in the escrow pool. The platform cannot issue credits against anticipated future funds.
Suspicious Activity Reporting (SAR)
When we identify activity that raises concern, we act. We file a Suspicious Activity Report (SAR) with FinCEN promptly when any of the following conditions are met:
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A transaction involves funds we have reason to believe are derived from illegal activity.
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A transaction appears designed to evade reporting requirements — including patterns that suggest structuring to stay below thresholds.
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A transaction does not make sense in the context of the customer's known profile, stated purpose, or typical behavior.
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A pattern of activity across one or more accounts suggests layering, integration of illicit funds, or coordinated evasion.
Confidentiality Notice: SAR filings are strictly confidential. We do not notify the subject of any SAR filing, as required by federal law. Any internal discussion of a pending or filed SAR must remain within the compliance team. All customer-facing team members complete annual AML/CFT training.