This SOP governs intake of cryptocurrency for:
- Investments in VICTORY bonds via Reg D (U.S. accredited) and Reg S (non‑U.S.) offerings
- No‑strings donations (non‑investment) to support eligible activities
See also: Legal Compliance Framework, Fundraising Models Comparison.
- Pre‑clearance
- Confirm open offering (Reg D or Reg S tranche) and current terms
- Assign deal‑specific deposit instructions (chain, asset, address/memo); do not reuse addresses across investors
- KYC/AML and Eligibility
- Collect KYC/AML (entity/individual), UBO disclosure, sanctions screening
- Reg D: verify accredited status (third‑party letter or issuer verification)
- Reg S: verify non‑U.S. person; confirm no U.S. directed selling; apply local‑law checks
- Subscription and Whitelisting
- Execute subscription docs (PPM, purchase agreement, risk factors)
- Whitelist investor wallet(s) for receipt; record chain, addresses, signing authority
- Funds Flow and Custody
- Accept approved assets (e.g., ETH/USDC) to deal address; on receipt, move to qualified custodian
- Create on‑chain and off‑chain receipts; reconcile FX rates and timestamps
- Issuance and Records
- Issue VICTORY bond allocation and any governance allocations per terms (subject to transfer restrictions/lockups)
- Record restrictions (Reg D: restricted; Reg S: distribution compliance) in cap table/registry
- Post‑Closing Controls
- Ongoing sanctions monitoring; travel rule compliance where applicable
- Investor communications per PPM; maintain audit trail
- Donation Channels
- Publish donation address(es) and supported assets for pure donations (no ROI, no consideration)
- Provide optional signed receipts for donor records (non‑tax advice)
- Firewalls and Use of Funds
- U.S. election activities: no foreign‑national funds; donations from non‑U.S. persons routed exclusively to non‑U.S. operations
- Maintain separate wallets and accounting for: (a) U.S. entities, (b) international ops, (c) grants/programs
- Recognition and Perks (Non‑Security)
- Allow badges/POAPs, donor walls, updates; no tokens or instruments implying ROI or entitlement
- No “donate and receive bonds/tokens” bundles (constitutes a sale of securities)
- No accepting funds without KYC/AML for investments
- No routing foreign‑national donations to U.S. independent expenditures
- If a prohibited transfer is detected: quarantine funds, notify counsel, file SARs as required, and refund where appropriate