Sanctions and Compliance

Version: 1.0 (draft)
Published: [Publication date]
Effective: [Effective date]

Draft, pending counsel review. Not in force. What this means

Aligner moves USDC, USDT and SOL between businesses and contributors, so it screens people, places and wallets. This page explains those checks and the tax data we collect before a payout.

1. Our commitment

[Aligner, Inc.] complies with the sanctions laws of the United States, including those administered by the Office of Foreign Assets Control (OFAC), and with the sanctions of the European Union, the United Kingdom and the United Nations, to the extent they apply to us or to our Users.

You may not use Aligner if you, your organization, or anyone who owns or controls it is a sanctioned person, or is located in a restricted jurisdiction.

2. Restricted jurisdictions

Restriction	Jurisdictions
No access	[Comprehensively sanctioned jurisdictions, e.g. Cuba, Iran, North Korea, Syria, and the Crimea, so-called DNR and LNR regions of Ukraine]
No funding of requests	Organizations located in Türkiye

Organizations located in Türkiye may not fund requests. Contributors located in Türkiye may accept offers and receive payouts.

[The list of restricted jurisdictions is to be confirmed by counsel and kept current as sanctions change.]

3. How we screen

At sign-up, you declare that you are not a sanctioned person and not located in a restricted jurisdiction. We check your IP address and may block access from restricted locations.
Before funding, we screen the team's funding wallet against sanctions and risk lists.
Before payout, we screen the contributor's receiving wallet the same way.
Over time, we may re-screen accounts and wallets when lists change.

[Wallet screening is not in place yet; confirm before publication.] Wallet screening is provided by [screening vendor]. Using a VPN or other tool to hide your location breaks these rules.

4. If a check fails

If a screen matches, or we have reason to believe these rules are broken, we may:

refuse to open an account, publish a request, accept funding or release a payout;
pause activity on the account while we review it, within what the escrow contract allows;
close the account;
report the matter to the authorities, and freeze or block funds, where the law requires it.

Where the law allows, we will tell you what happened and how to ask for a review.

5. Data we collect before a payout

Before your first payout, we ask for tax information. Teams are the payers and remain responsible for their own withholding; we collect this data so it is available and so we can meet our own reporting duties.

Who	What we collect
US persons	IRS Form W-9
Non-US persons	IRS Form W-8BEN (individuals) or W-8BEN-E (entities)
Residents of the European Union	The data required by EU Directive 2021/514 (DAC7): full name, address, date of birth, tax identification number and payout account details

Aligner reports DAC7 data to the tax authority of [EU Member State of DAC7 registration], which shares it with the tax authorities of the contributor's country of residence. We tell you what we report each year.

6. When fuller identity checks apply

Most accounts only need the payout data above. We may ask for a full identity check, through a third-party provider, when:

your payouts or funding pass [thresholds to be confirmed by counsel];
a screen returns a possible match;
we see signs of fraud, money laundering or sanctions evasion;
the law requires it.

How identity checks work is described in Verification and Work Proofs.

7. Anti-money laundering

You may not use Aligner to launder money, finance terrorism, evade taxes or move proceeds of crime. Requests must reflect real work at a real price.

We cooperate with lawful requests from law enforcement and regulators, and we keep records for as long as the law requires.

8. Contact

Questions about sanctions or payout data go to [legal@aligner.network].

Version history

Version 1.0 (draft)[Publication date]First draft for counsel review.