Anti-Money Laundering (AML) Policy

1. Purpose

The headacheMD for all Foundation (the "Foundation") adopts this Anti-Money Laundering (AML) Policy to:

• Comply with applicable federal and state laws and regulations regarding anti-money laundering and counter-terrorist financing;
• Establish procedures to verify the identity of donors and the source of funds where appropriate;
• Detect and report suspicious activity;
• Maintain records as required by law or sound practice;
• Train personnel on AML obligations and red flags.

2. Scope

This policy applies to all donations, grants, and other monetary or in-kind contributions received by the Foundation. It applies to all staff, board members, volunteers, and contractors who solicit, process, or have access to donor information or financial transactions.

3. Designated Compliance Officer

The Foundation shall designate an AML Compliance Officer (who may also serve as the general Compliance Officer) responsible for:

• Implementing and overseeing this policy;
• Reviewing donor due diligence and unusual activity;
• Making or coordinating suspicious activity reports (SARs) if required;
• Ensuring AML training is provided;
• Periodically reviewing and updating this policy.

4. Donor Due Diligence

The Foundation will conduct reasonable due diligence on donors consistent with the size and nature of contributions and the Foundation's risk profile.

4.1 General Donations

For routine donations (e.g., small to moderate one-time or recurring gifts), the Foundation will collect and retain basic donor information (name, contact information, and payment method) as part of normal recordkeeping.

4.2 Enhanced Due Diligence

For larger or unusual contributions, or when red flags are present, the Foundation may:

• Verify donor identity and address;
• Inquire about the source of funds or the purpose of the donation;
• Document the basis for accepting or declining the donation;
• Consult with the Compliance Officer or legal counsel as needed.

5. Red Flags and Suspicious Activity

Staff and volunteers should be alert to circumstances that may indicate money laundering or other illicit activity, including but not limited to:

• Donor reluctance to provide identity or source-of-funds information;
• Donations in cash or multiple smaller payments that appear structured to avoid reporting thresholds;
• Donations from high-risk jurisdictions or entities on sanctions lists;
• Inconsistent or implausible explanations for the donation;
• Pressure to complete a transaction quickly or without documentation;
• Donor requests for repayment or use of funds in an unusual manner;
• Any other activity that seems designed to obscure the origin or use of funds.

Any observed red flags or suspicious activity must be reported promptly to the Compliance Officer without informing the donor.

6. Reporting

If the Foundation determines that a transaction or pattern of activity is suspicious and may relate to money laundering or terrorist financing, it will:

• Document the facts and basis for the determination;
• Consult with legal counsel regarding any obligation to file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN) or other authorities;
• Refrain from completing or accepting the transaction if doing so would facilitate illegal activity;
• Maintain confidentiality of any SAR filing to avoid "tipping off" the subject.

7. Record Retention

Donor and transaction records related to AML will be retained in accordance with the Foundation's Document Retention and Destruction Policy and applicable law (typically at least five years). Records will be made available to regulators or law enforcement upon proper request.

8. Training

The Foundation will provide AML awareness training to staff, board members, and volunteers who handle donations or donor information. Training will cover this policy, red flags, and reporting procedures, and will be updated as needed.

9. Policy Review

This policy will be reviewed annually by the Board of Directors (or a designated committee) and the Compliance Officer to ensure it remains effective and consistent with current law and the Foundation's risk profile. Updates will be made as necessary.

10. Contact Information

For questions about this policy or to report a concern, contact:

headacheMD for all Foundation
Compliance Officer
Email: info@headacheMD.org
Phone: (713) 426-3337
Address: 2410 Ella Blvd, Suite C, Houston, TX 77008