Internal Investigation & Audit Policy

1. Investigation Triggers

Investigations are initiated under the following circumstances:

• Transaction Anomalies: Sudden spikes in volume or suspicious payment patterns.
• Identity Mismatches: Failure to re-verify via ProntoID or conflicting KYC data.
• Third-Party Reports: Validated complaints from consumers, other creators, or financial institutions.
• Compliance Audits: Routine spot-checks for 2257 record-keeping and model release validity.

2. The Audit Process

Our compliance team follows a multi-step protocol to resolve internal investigations:

1. Data Collection: We extract all relevant transaction logs and metadata associated with the account or asset in question.
2. Verification Linkage: We cross-reference the activity against the ProntoID identity vault and Pronto Tag history to ensure the person performing the action is the authorized account holder.
3. Communication: If necessary, we issue a "Request for Information" (RFI) to the user. Accounts may be restricted during this period to prevent loss of funds.
4. Final Adjudication: Based on the evidence, we may clear the account, issue a warning, or proceed with permanent termination and reporting to relevant authorities.

3. Cooperation with Financial Partners

BentBox maintains an open-door policy for payment processors and acquiring banks. In the event of a chargeback dispute or a fraud inquiry, our team provides full transparency by sharing:

• Evidence of ProntoID age and identity verification.
• IP logs and device fingerprints associated with the transaction.
• Signed model releases or licensing agreements where applicable.

4. Law Enforcement & Regulatory Disclosure

BentBox complies with all valid legal requests from law enforcement agencies. We maintain records in accordance with 18 U.S.C. § 2257 and will disclose investigation findings when required by subpoena or to prevent immediate harm to our community.