Legal & Compliance

Compliance with Applicable Laws

All Participants shall comply with all applicable laws, rules, and regulations in connection with their participation in the SAP, including those related to data privacy, consumer protection, advertising, securities, anti-money laundering, and anti-corruption. Participants are responsible for understanding and complying with the legal and regulatory requirements applicable to their activities in their respective jurisdictions.

Anti-Corruption and Anti-Bribery

No SAP funds, resources, or program benefits may be used, directly or indirectly, for payments or anything of value to any government official or employee, political party, official of a political party, candidate for political office, or anyone acting in an official capacity, in order to obtain, retain, or direct business or obtain any improper advantage. Participants shall conduct all program-related activities in compliance with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act of 1977, as amended, the UK Bribery Act 2010, and any similar laws in any applicable jurisdiction. Participants shall promptly notify SDF if they become aware of any potential violation of this provision.

Sanctions Compliance

Participants shall not, directly or indirectly, facilitate or further any transactions or engagement with jurisdictions that are the target of comprehensive economic or financial sanctions imposed by the United States (including OFAC), the European Union, the United Kingdom, or the United Nations (“Sanctioned Jurisdictions”), or with any persons or entities designated on sanctions-related restricted party lists maintained by those authorities (“Sanctioned Persons”). Participants represent that they are not, and shall not become, Sanctioned Persons and are not located, organized, or ordinarily resident in a Sanctioned Jurisdiction. Participants shall immediately notify SDF if any of the foregoing representations ceases to be true.

Anti-Money Laundering

Participants shall not use any SAP funds, resources, or program benefits in connection with money laundering, terrorist financing, fraud, or any other illicit financial activity. All funds and assets used in connection with the SAP must be derived from lawful sources.

Government Engagement

SAP activities, content, and events should not target any national, provincial, state, local, or municipal governments or government officials, or any governmental or quasi-governmental entities or organizations, unless expressly approved by SDF in writing. Participants shall not engage with, or make any communication to, any governmental, regulatory, or self-regulatory authority on behalf of SDF or purporting to represent SDF without SDF’s prior written approval. Participants shall promptly notify SDF of any request from such an authority directed to SDF that they become aware of in connection with the SAP.

Role of SDF; Independent Chapters

SDF administers the SAP and provides funding and resources aligned with mutually agreed goals to support Stellar ecosystem growth. SDF's role is that of a program facilitator and funder. SDF does not control the day-to-day activities of any chapter, Lead Organization, Chapter Lead, Ambassador, or other Participant.

Each chapter is managed and operated by its respective Lead Organization. Lead Organizations, Chapter Leads, Ambassadors, and all other Participants are not employees, agents, or joint venturers of SDF. No Participant has the authority to bind SDF, make commitments on SDF's behalf, or represent themselves as acting for SDF in any capacity. Any views, actions, commitments, or representations made by any Participant are solely their own and do not reflect the positions, obligations, or endorsements of SDF.

No Guarantee of Funding

Participation in the SAP, in any capacity, does not guarantee funding, compensation, or any other economic benefit from SDF. All funding decisions are made by SDF in its sole discretion and are subject to program requirements, eligibility, availability, and applicable terms. Participants should not represent to any third party that SDF has committed to, or will provide, funding in connection with any project, event, or initiative unless SDF has confirmed such commitment in writing. For information about specific funding opportunities and their official rules, Participants should refer to the applicable program pages and official guidelines.

Content and Activities

All SAP-related content and activities are for educational and informational purposes. Participants shall not provide investment advice, promote market speculation (including speculation regarding XLM), make false or misleading claims, or claim that any content or event is created, hosted, or endorsed by SDF without SDF's explicit prior written approval. All content funded through or associated with the SAP should aim to educate, engage, or onboard ecosystem participants and must comply with the Content and Events Policy and SDF Brand Policy.

Reporting Violations

Participants who become aware of any potential violation of these Legal & Compliance requirements, or of any applicable law, should promptly report the matter to SDF at [e-mail]. SDF will review all reports and may take appropriate action, including removal from the program and recovery of funds.

Modifications

SDF reserves the right to update these Legal & Compliance requirements from time to time. Participants are responsible for reviewing and complying with the most current version of these requirements. Continued participation in the SAP following any update constitutes acceptance of the updated requirements.