PlatformDTC

AML & Compliance Policy

Last Updated: April 19, 2026

Legalize Freedom LLC, a Delaware limited liability company doing business as "PlatformDTC" ("PlatformDTC", "we", "us") is committed to preventing money laundering, terrorist financing, sanctions evasion, fraud, and other financial crimes on our platform. This Compliance Policy describes our framework, controls, and the obligations of our users.

1. Regulatory Framework

PlatformDTC's compliance program is designed to align with:

  • US Bank Secrecy Act (BSA) and USA PATRIOT Act
  • Office of Foreign Assets Control (OFAC) sanctions regulations
  • Financial Crimes Enforcement Network (FinCEN) guidance
  • IRS reporting requirements including 1099-K issuance
  • EU Anti-Money Laundering Directives (AMLD) for European Customers and Brand Owners
  • UK Money Laundering Regulations for UK Customers and Brand Owners
  • Stripe's compliance requirements as our payment processor
  • Card network rules (Visa, Mastercard, American Express, Discover)
  • Applicable consumer protection and privacy laws (CCPA, GDPR)

Note: PlatformDTC is not a regulated financial institution. Payment processing, money transmission, and core financial functions are performed by Stripe, which is a regulated payment processor. PlatformDTC implements compliance controls as the platform on top of Stripe.

2. Compliance Program Pillars

2.1 Know Your Customer (KYC)

Every Brand Owner must complete identity verification before processing live payments, including:

  • Legal name and date of birth
  • Government-issued ID (passport, driver's license, national ID)
  • Address verification (utility bill, bank statement, lease)
  • Tax identification number (SSN, EIN, ITIN, or non-US equivalent)
  • Beneficial ownership disclosure for entities (anyone owning ≥25%)
  • Business documentation (articles of incorporation, business license, where applicable)
  • Bank account verification

KYC is conducted via Stripe Identity and Stripe's Connect onboarding flows, supplemented by PlatformDTC's own checks where appropriate.

2.2 Customer Due Diligence (CDD)

Beyond identity verification, we assess each Brand Owner's:

  • Nature of business
  • Products or services offered
  • Expected transaction volume and average ticket size
  • Geographic markets served
  • Source of funds (where applicable)

2.3 Enhanced Due Diligence (EDD)

We apply additional scrutiny — including more frequent reviews, source-of-funds documentation, and senior management approval — for Brand Owners that:

  • Operate in higher-risk industries (where permitted)
  • Process unusually high volumes
  • Are located in or transact with higher-risk jurisdictions
  • Include politically exposed persons (PEPs) among beneficial owners
  • Show elevated chargeback or fraud rates
  • Are flagged by sanctions screening or adverse media

2.4 Sanctions and PEP Screening

All Brand Owners and beneficial owners are screened against:

  • OFAC Specially Designated Nationals (SDN) list
  • OFAC Sectoral Sanctions Identifications (SSI) list
  • UN Consolidated Sanctions List
  • EU Consolidated List of Persons, Groups and Entities subject to EU Financial Sanctions
  • UK HM Treasury Sanctions List
  • Politically Exposed Persons (PEP) databases

Screening is performed at onboarding and periodically thereafter. Matches result in account decline or, for existing accounts, suspension and reporting.

2.5 Transaction Monitoring

We monitor transactions for indicators of suspicious activity, including:

  • Rapid escalation in transaction volume
  • Transactions inconsistent with declared business model
  • "Structuring" — multiple transactions just below reporting thresholds
  • Cross-border activity to/from higher-risk jurisdictions
  • Unusual patterns of refunds, chargebacks, or reversals
  • Transactions linked to known fraud patterns or compromised cards
  • Use of multiple accounts by linked parties

We rely on Stripe Radar for real-time fraud screening and supplement with platform-level checks.

2.6 Suspicious Activity Reporting

When we identify activity that may indicate money laundering, terrorist financing, sanctions evasion, or other financial crime:

  • We may freeze funds pending investigation
  • We file Suspicious Activity Reports (SARs) with FinCEN where required and permitted
  • We notify Stripe and cooperate with their investigations
  • We do not disclose to the subject of a report that a SAR has been filed ("no tipping off")
  • We retain records for at least 5 years

2.7 Record Keeping

We retain compliance records for the longer of:

  • 5 years from account closure (KYC, CDD, transaction monitoring records)
  • 7 years for tax and financial transaction records (IRS requirement)
  • Longer where required by specific regulations or pending investigations

3. Restricted and Prohibited Activities

We do not permit:

  • Use by individuals or entities on sanctions lists
  • Operation from OFAC-sanctioned countries (Cuba, Iran, North Korea, Syria, Crimea, and other restricted regions)
  • Business categories prohibited by our Acceptable Use Policy
  • Business categories prohibited by Stripe (see https://stripe.com/legal/restricted-businesses)
  • Money services businesses (MSBs) without prior written approval and licensing
  • Activities that violate US export controls or international sanctions

4. Tax Reporting (US)

For US Brand Owners meeting IRS thresholds, Stripe issues Form 1099-K on PlatformDTC's behalf reporting gross payment volume processed through the platform during the calendar year.

  • Brand Owners must provide accurate W-9 (US persons) or W-8 (non-US persons) information when prompted
  • 1099-K forms are made available to Brand Owners by January 31 of the following year and to the IRS by IRS deadlines
  • Brand Owners are responsible for their own income, sales, VAT, and other tax obligations

5. Brand Owner and Customer Obligations

By using PlatformDTC, you agree to:

  • Provide accurate identity, business, and tax information
  • Update us within 30 days of any material change (ownership, address, business model)
  • Cooperate with KYC refresh and source-of-funds inquiries
  • Not engage in any activity prohibited by this policy, the AUP, or applicable law
  • Report suspicious activity you observe to compliance@platformdtc.com

Failure to cooperate may result in account suspension or termination, and funds may be held while investigations are completed.

6. Reporting Concerns

We encourage anyone — Brand Owners, Customers, employees, or external parties — to report compliance concerns:

Reports may be made anonymously where permitted. We do not retaliate against good-faith reporters.

7. Compliance Governance

Acting Compliance Officer: Phi Thang Mai, Member, Legalize Freedom LLC Email: compliance@platformdtc.com

Our Compliance Officer is responsible for the design, implementation, and ongoing monitoring of our compliance program. The Compliance Officer has independent authority to investigate concerns, freeze accounts, file suspicious activity reports, and make compliance decisions. As the platform scales, we plan to appoint a dedicated full-time Compliance Officer.

8. Independent Review

PlatformDTC's compliance program is reviewed annually, and as the platform scales. Material changes to our risk profile or regulatory environment trigger immediate review and update of this policy.

9. Limitations

This policy describes our compliance commitments and obligations of users. It does not:

  • Create legal rights for third parties beyond those required by law
  • Substitute for legal advice
  • Cover every possible regulatory scenario

We update this policy as regulations evolve. Material changes will be communicated at least 14 days in advance.

10. Contact