Whistleblowing Policy

Last Updated: December 16, 2025

Our commitment

Dream Finance US LLC is committed to integrity, transparency, and full compliance with U.S. federal and state laws, including requirements applicable to Money Services Businesses (MSBs), Money Transmitters (MTLs), and Virtual Asset Service Providers (VASPs).

If you observe behavior that appears illegal, unethical, unsafe, discriminatory, or improper, you can safely report it through our internal or anonymous channels.

We strictly prohibit any form of retaliation against individuals who report concerns in good faith. All reports are handled confidentially, professionally, and with respect for your rights.

What you can report

We encourage reporting concerns related to:

Money laundering, terrorist financing, or sanctions violations
Fraud, corruption, bribery, or financial misconduct
Violations of federal or state regulatory requirements, including:
- Bank Secrecy Act (BSA)
- FinCEN MSB regulations
- Office of Foreign Assets Control (OFAC) sanctions
- State Money Transmitter laws and rules
- Consumer protection or unfair business practices
Unethical, abusive, harassing, discriminatory, or inappropriate workplace behavior
Data protection, cybersecurity incidents, or unauthorized system access
Violations of internal policies or codes of conduct
Misconduct that harms clients, employees, partners, or the public

If you are unsure – report anyway. We review every submission.

Your protection

We are committed to maintaining a safe and supportive environment where anyone can report concerns without fear of retaliation or exposure. Consistent with applicable U.S. whistleblower protection laws, employees who report concerns in good faith are protected from retaliation. Any adverse action taken against an individual for making a good-faith report is strictly prohibited.

When you report a concern:

Your identity is kept confidential.
You may report anonymously.
Retaliation, threats, or negative treatment are strictly prohibited.
Reports are reviewed fairly, objectively and without delay.

Review Process and Timelines

We ensure that every report is assessed fairly, impartially, and without delay.

Acknowledgement: We confirm receipt of your report within 3 business days.
Review timeline: Our goal is to complete the initial assessment and investigation within 30 days.
If more time is needed due to complexity, we will keep you informed.

How to report

You may report a concern through any of the following channels:

Anonymous online form (below on this page)
Email: [email protected]
Handling based on topic:
- For AML/financial crime: handled by the MLRO
- For unethical behaviour: handled by HR

We ensure appropriate separation of duties and confidentiality throughout.

External Reporting

In cases where internal reporting is not possible or appropriate, or if the whistleblower prefers to report externally, the following competent authorities in the United States may be used:

In cases where internal reporting is not possible or appropriate, or if a reporter prefers to report externally, the following authorities may be used for submitting reports of illegal conduct, financial misconduct, whistleblower disclosures, etc.

Financial Crimes Enforcement Network (FinCEN)
For suspected money laundering, terrorist financing, or MSB violations, you may submit a tip directly to FinCEN.
- FinCEN Tips & Complaints Portal: https://www.fincen.gov/contact
Office of Foreign Assets Control (OFAC)
For concerns about sanctions violations:
- OFAC Hotline: 1-800-540-6322
- OFAC Compliance Reporting: https://home.treasury.gov/policy-issues/financial-sanctions
Consumer Financial Protection Bureau (CFPB)
If the matter relates to consumer harm, unfair practices, unauthorized transfers, or remittance issues:
- Submit a complaint: https://www.consumerfinance.gov/complaint/
- Phone: (855) 411-2372
State Banking / Financial Regulators
For issues related to money transmitter licensing or state consumer protection, whistleblowers may contact the relevant state regulator where the service was provided.
U.S. Department of Justice (DOJ)
For serious misconduct, criminal fraud, corruption, or federal offenses:
- Report to DOJ: https://www.justice.gov/doj/webform/your-message-department-justice
- FBI Tip Line: https://tips.fbi.gov

Make a report

To help us review your report effectively, please include all information you feel comfortable sharing. A clear message should generally describe what happened, when and where the situation occurred, and who was involved (names, positions, or roles). Please focus on the facts you personally observed, including any actions or behavior that raised concerns, as well as relevant context such as whether this was a one-time or repeated incident. If available, you may also mention any supporting evidence that you have (e.g., documents, messages, screenshots). Finally, it is helpful to explain why the situation is concerning to you, any potential risks or consequences, and any additional details that may help us better understand the issue.

Below are the choices available to you. Please select the type of report you would like to make:

Money laundering, terrorist financing, sanctions violations
Fraud, corruption, bribery, financial misconduct
Violations of regulations
Unethical, abusive, discriminatory, or inappropriate behaviour
Data protection or cyber-security issues
Breaches of internal policies or professional standards
Any misconduct that could harm the company, clients, or the public