Compliance Policies

Anti-Money Laundering (AML) Policy

Legal Entity Notice
This policy is issued by DEAL ROOM LLC, doing business as The Solist (“we,” “us,” “our”), and applies to all services, transactions, and operations conducted through our website at www.thesolist.com.

1. Purpose

The purpose of this Anti-Money Laundering (AML) policy is to prevent The Solist from being used for money laundering, terrorism financing, or other illicit financial activities. We are committed to legal compliance and ethical business conduct.

2. Scope

This policy applies to all employees, departments, and third-party partners involved with The Solist.

3. Regulatory Framework

We operate in alignment with:

  • The Bank Secrecy Act (BSA)

  • USA PATRIOT Act

  • Financial Action Task Force (FATF) guidelines

4. Risk-Based Approach

Customer and transaction risk is assessed based on:

  • Geographic location

  • Purchase frequency and volume

  • Nature of goods and payment methods

5. Monitoring and Reporting

We maintain the following controls:

  • Transactions over $10,000 may trigger enhanced review.

  • Suspicious activity is flagged and escalated internally.

  • Suspicious Activity Reports (SARs) may be filed with the relevant authorities.

  • We block transactions to Cuba, Iran, North Korea, Syria, Russia, Belarus, and the Crimea, Luhansk, and Donetsk regions of Ukraine.

  • VPNs, third-party freight forwarders, or PO boxes used to mask sanctioned locations are flagged.

6. Staff Training

Employees undergo mandatory AML training during onboarding and annually thereafter.

7. Recordkeeping

We retain identity and transaction records for at least 5 years in accordance with legal requirements.

8. Review

This policy is reviewed annually and updated as needed.

Know Your Customer (KYC) Policy

Legal Entity Notice
This policy is issued by DEAL ROOM LLC, doing business as The Solist (“we,” “us,” “our”), and applies to all services, transactions, and operations conducted through our website at www.thesolist.com.

1. Purpose

Our Know Your Customer (KYC) policy helps verify customer identity, detect fraud, and comply with global regulations.

2. Customer Identification Program (CIP)

For select transactions, we may require:

  • Full legal name

  • Billing and shipping address

  • Government-issued ID

  • Payment method verification

We may use trusted third-party providers for identity validation.

3. Enhanced Due Diligence (EDD)

EDD procedures apply to:

  • High-value purchases (e.g., above $10,000)

  • Customers from high-risk or sanctioned jurisdictions

  • Mismatched billing/shipping data or third-party payments

EDD includes:

  • Identity and address re-verification

  • Source of funds confirmation

  • Screening against watchlists

  • Blocking shipping to embargoed countries and regions

4. Data Protection

All collected information is stored securely and handled per our Privacy Policy and applicable data protection laws (e.g., GDPR, CCPA).

Sanctions Compliance Policy

Legal Entity Notice
This policy is issued by DEAL ROOM LLC, doing business as The Solist (“we,” “us,” “our”), and applies to all services, transactions, and operations conducted through our website at www.thesolist.com.

1. Purpose

This policy ensures we do not engage in commerce or services with individuals, entities, or jurisdictions subject to international sanctions, and outlines our controls to prevent prohibited sales.

2. Jurisdictions Covered

We prohibit any sale, shipment, or service to individuals or entities located in:

  • Cuba

  • Iran

  • North Korea

  • Syria

  • Russia

  • Belarus

  • Crimea, Luhansk, and Donetsk regions of Ukraine

This applies regardless of nationality or payment origin.

3. Technical & Procedural Controls

  • IP blocking from known restricted regions

  • Automated checkout restrictions for shipping to sanctioned areas

  • Payment processor screening for suspicious sources (e.g., Russian MIR cards)

  • Manual compliance review queue for flagged transactions

  • Vendor compliance agreements for dropshipped or third-party items

4. Prohibited Transactions

We do not engage with:

  • Individuals or companies on the OFAC SDN list

  • EU Consolidated Sanctions List members

  • PEPs (politically exposed persons) without additional due diligence

5. Escalation and Reporting

Suspected violations are:

  • Flagged by compliance systems

  • Reviewed by compliance officers

  • Reported to OFAC or relevant regulators as necessary

6. Employee Oversight

Employees involved in order processing, finance, or customer operations receive sanctions training annually and as needed for updates.