Fundraising Policy

General Organization Information

Full Legal Name of Organization: Brain Drain Unlimited Foundation Legal Address: 8 The Green, Suite 8426, Dover, DE 19901

Organization’s Mission and Goals

Brain Drain Unlimited Foundation’s mission is to turn conflict-driven brain drain into an advantage for U.S. innovation. We partner with engineers, scientists, and healthcare professionals displaced by conflict, helping them navigate U.S. immigration and turning uncertainty into momentum.

We provide step-by-step support – from visa strategy (EB-1, EB-2 NIW, O-1) and credential validation to career coaching and community connections. Our goal is to ensure talented individuals don’t just arrive in America – they thrive.

Since 2022, we’ve united legal experts, employers, volunteers, and donors around a single purpose: transforming resilience into impact. Every professional we help rebuilds a career, fills a critical skills gap, and fuels local innovation.

We invite you to join a movement that turns adversity into progress – for individuals, communities, and the future of U.S. innovation.

Purpose: The Corporation is a nonprofit corporation, exclusively charitable, educational, and nonprofit, as defined under Section 501(c)(3) of the Internal Revenue Code of 1986, as1 amended. Our primary purpose is to support refugees of Russian aggression.

Date of Incorporation and 501(c)(3) Status

Brain Drain Unlimited Foundation was incorporated in the State of Delaware on December 19, 2023 (File Number 27866578). The organization is a recognized 501(c)(3) nonprofit, meaning donations to us are tax-deductible in accordance with U.S. law.

Brief Description of Key Programs and Activities

We achieve our mission through four core programs:

“Support for Talented Professionals” Program

Provides comprehensive informational and mentorship support for talented individuals interested in relocating and developing their careers in the USA. This includes assistance with obtaining a talent visa, integrating into the professional community, and financial support for key relocation stages (document translation, fees, lawyer consultations, transportation, temporary housing, etc.).

“Community of Opportunities” Program

Offers legal support and necessary resources for individuals already in the USA on legal temporary status who are interested in changing it to a more permanent one, aiming for legalization and integration into American society. This includes free legal consultations, informational sessions, and practical assistance during the legalization process.

“Community Bridges and Development” Program

Fosters connections within immigrant and American communities, raises awareness on immigration issues, advocates for positive immigration changes, and provides practical assistance to partner non-profit organizations and community members by leveraging the BrainDrain network. This includes educational initiatives, advocacy, and the “BrainDrain Helping Hands” mutual aid program.

“Talent Bridge: Extraordinary Minds Welcome” Program

This program leverages the diverse talents within our BrainDrain community by offering a wide range of professional services (e.g., web development, translation, digital marketing, legal consultations, business consulting). Our goal is to provide opportunities for our members to gain valuable work experience and income, and to generate a sustainable funding source for the foundation’s other non-profit initiatives. Revenue from services rendered is reinvested to support our core programs.

Names and Roles of Key Personnel

Board of Directors

The highest governing body of the organization, responsible for strategic decisions and oversight of activities. Includes Co-Founders Manus MacLean and Konstantin Samoilov, as well as a rotating board of up to 9 additional members.

Officers

• President: Konstantin Samoilov
• Treasurer: Manus MacLean
• Information on other key staff members and roles is available upon request.

Current Governance Structure

Our organization has a Fundraising Committee responsible for developing and implementing the Fundraising Policy. The Executive Director holds overall responsibility for policy implementation, with financial oversight provided by the Treasurer.

Existing Fundraising Practices

• We currently use and plan to utilize a variety of fundraising methods, including:
• Direct donations (via our website and other channels)
• Grants from foundations and organizations
• Fundraising events
• Crowdfunding campaigns
• Corporate donations
• Bequests and planned giving

Internal Rules and Procedures Regarding Donations

Acceptance of any contribution, gift, or grant is at the discretion of the Brain Drain Unlimited Foundation. The Brain Drain Unlimited Foundation will not accept any gift unless it can be used or expended consistently with the purpose and mission of the Brain Drain Unlimited Foundation.

No irrevocable gift, whether outright or life-income in character, will be accepted if, under any reasonable set of circumstances, the gift would jeopardize the donor’s financial security.

The Brain Drain Unlimited Foundation will refrain from providing advice about the tax or other treatment of gifts and will encourage donors to seek guidance from their own professional advisers to assist them in the process of making their donation.

The Brain Drain Unlimited Foundation will accept donations of cash or publicly traded securities. Gifts of in-kind services will be accepted at the discretion of the Brain Drain Unlimited Foundation.

Certain other gifts, real property, personal property, in-kind gifts, non-liquid securities, and contributions whose sources are not transparent or whose use is restricted in some manner must be reviewed prior to acceptance due to the special obligations raised or liabilities they may pose for Brain Drain Unlimited Foundation.

The Brain Drain Unlimited Foundation will provide acknowledgments to donors meeting tax requirements for property received by the charity as a gift. However, except for gifts of cash and publicly traded securities, no value shall be ascribed to any receipt or other form of substantiation of a gift received by Brain Drain Unlimited Foundation.

The Brain Drain Unlimited Foundation will respect the intent of the donor relating to gifts for restricted purposes and those relating to the desire to remain anonymous. With respect to anonymous gifts, the Brain Drain Unlimited Foundation will restrict information about the donor to only those staff members with a need to know.

The Brain Drain Unlimited Foundation will not compensate, whether through commissions, finders’ fees, or other means, any third party for directing a gift or a donor to the Brain Drain Unlimited Foundation.

Donor Database and Third-Party Fundraisers

We maintain a donor database, which we plan to actively expand. We utilize both internal staff and third-party fundraisers or consultants as needed, in accordance with our policy and ethical principles.

Fundraising Goals and Objectives

Our fundraising goals are divided into short-term and long-term objectives and are aimed at funding all our programs and operational activities.

Short-Term Goals (6-12 months)

“Support for Talented Professionals” Program

• Case Preparation Funding: Cover initial visa application costs (translations, tests, lawyer consultations) for 5-10 applicants.
• Mentorship Program Launch: Raise funds for online platform development and initial meetings.
• Webinar Hosting: Secure funding for experts to lead 3-5 informational sessions.

“Community of Opportunities” Program

• Legal Consultations: Fund free initial consultations for 10-20 individuals seeking status changes.
• Informational Sessions: Organize 2-3 public sessions on immigration law.
• Legal Aid Mini-Fund: Create a small reserve for urgent expenses (translations, notarization).

“Community Bridges and Development” Program

• Educational Webinars: Fund 3-5 webinars for the general public on immigration issues.
• Informational Materials: Raise funds for developing and distributing brochures and guides.
• “Brain Drain Helping Hands” Launch: Secure funds to create a volunteer database and coordinate their work for partner non-profits.

“Talent Bridge: Extraordinary Minds Welcome” Program

• Initial Platform Development: Raise funds for the development and launch of the online platform for offering professional services.
• Marketing Initiatives: Secure funding for initial marketing campaigns to attract clients and raise program awareness.
• Professional Stipends: Establish a small fund to provide targeted financial assistance to Brain Drain professionals needing support to participate in the program (e.g., for equipment or training).

Long-Term Goals (1-3+ years):

“Support for Talented Professionals” Program

• “Talent Relocation Fund”: Establish a sustainable fund for comprehensive financial assistance (visas, relocation, housing) for a continuous stream of talented individuals.
• Platform Endowment: Ensure ongoing development and support for the online platform.
• Strategic Partnerships: Cultivate long-term relationships with companies and associations to sponsor services.

“Community of Opportunities” Program

• “Legal Aid Fund”: Establish a substantial fund for comprehensive legal support and representation in status change cases.
• Legal Partnerships: Develop collaborations with law firms for pro bono or reduced-fee services.
• Assistant Training: Launch a program to train volunteers to expand aid capacity.

“Community Bridges and Development” Program

• Advocacy & Education Fund: Establish a sustainable fund for advocacy and large-scale educational initiatives.
• Sustainable Partnership Network: Develop long-term relationships with non-profits, businesses, and educational institutions.
• “Ambassador” Program: Fund the training and support of community members to spread information and foster integration.

“Talent Bridge: Extraordinary Minds Welcome” Program

• Service Portfolio Expansion: Continuously develop and add new professional services to meet market demands and community talents.
• Mentorship and Career Development Program: Establish a sustainable program for the professional growth and skill development of BrainDrain program participants.
• Global Partnerships: Forge strategic partnerships with international companies and organizations to expand the client base and provide work opportunities beyond the U.S.
• Research and Innovation Fund: Create a fund to support research projects and innovative initiatives developed by members of the BrainDrain community.

Organizational Expenses

Funds raised will be used to cover the following expenses:

• Programmatic Expenses: Direct funding for all four of our programs, including direct assistance to applicants, payment for legal services, event hosting, and material development.
• Other Expenses: Administrative costs, staff salaries, subscription fees for software and services, and other operational expenses necessary for the efficient functioning of the organization.

Fundraising Budget

We maintain an annual fundraising budget, which is regularly reviewed and approved by the Board of Directors.

Legal and Regulatory Aspects

Fundraising Registration Requirements (Delaware)

We are aware that the State of Delaware does not require charitable organizations to register for fundraising at the state level for most cases. Nevertheless, we will monitor any legislative changes and potential exceptions (e.g., for charitable annuities or requirements in certain counties) and comply with all applicable regulations.

Compliance with Federal IRS Requirements

Brain Drain Unlimited Foundation is a 501(c)(3) nonprofit organization and plans to file Form 990 annually with the Internal Revenue Service (IRS), adhering to all federal reporting requirements for nonprofit organizations.

Disclosure of Donations and Donors

Every donation will be disclosed in accordance with applicable laws. We understand that some states may require disclosure of large donations, and we will comply with these requirements as necessary. Information regarding donors who wish to remain anonymous will be restricted to only those staff members who need to know this information for processing the donation.

Compliance with Anti-Fraud Laws

Brain Drain Unlimited Foundation adheres to strict procedures to prevent fraud and ensure the legality of all fundraising operations. We commit to:

• Thoroughly vet all donations: We will make reasonable efforts to ensure that all donations come from legitimate sources and are not connected to criminal activity or money laundering. Should reasonable suspicion arise, we reserve the right to decline or return the donation.
• Transparency and accountability: We will publicly report on the use of funds and ensure financial information is accessible in accordance with our obligations.
• Internal controls: Implement and maintain robust internal control systems to protect the organization’s assets and prevent misuse of funds.
• Legal compliance: Adhere to all applicable federal and state laws regarding fundraising, anti-fraud measures, and financial reporting.

Ethical Principles and Accountability

Brain Drain Unlimited Foundation builds its fundraising activities on the following ethical principles:

• Transparency: We commit to being as open as possible regarding our goals, programs, use of funds, and financial reporting.
• Integrity: All our communications and fundraising appeals will be honest, accurate, and not misleading.
• Respect for Donors: We will respect donors’ rights and wishes, including their right to anonymity, where applicable, and their preferences regarding the use of funds.
• Donor Information Confidentiality: We will protect donors’ personal information and will not sell, trade, or rent their data to third parties without their explicit consent, except where required by law.
• Purposeful Use of Funds: We commit to using donations in accordance with the stated goals and mission of the organization.
• Professionalism: All staff and volunteers involved in fundraising will act professionally and ethically.

Ensuring Accountability and Transparency

Accountability and transparency are fundamental to Brain Drain Unlimited Foundation. We ensure them through the following means:

• Donor Reporting: We will provide donors with regular updates on our achievements and the use of funds, as well as donation acknowledgments for tax purposes.
• Internal Audit: Regular internal audits will be conducted to ensure financial discipline and adherence to internal procedures.
• Public Reporting on Website: Financial information and reports on our activities will be available on our website, allowing the public to track our work.
• Independent Audit: We aim to conduct independent external audits of our financial activities as the organization grows.

Donor Management

We strive to build strong and long-lasting relationships with our donors, based on mutual respect and trust. This is achieved through:

• Acknowledgements: Timely and sincere expression of gratitude for every donation.
• Regular Reports: Providing donors with regular updates on how their contribution helps achieve the organization’s mission (publicly on the website and via direct communications).
• Events: Organizing events that allow donors to learn more about our work and meet beneficiaries and staff.

No minimum or maximum donation amounts are set. We value every contribution, regardless of its size.

In-Kind Donations

We accept certain in-kind donations. Gifts of in-kind services are accepted at the discretion of the Brain Drain Unlimited Foundation.

The valuation and accounting for in-kind donations will be carried out as follows:

• Services: For services provided pro bono, no monetary value will be assigned to donor receipts, but their value will be tracked for internal purposes and reported to the Board of Directors.
• Goods/Property: For tangible in-kind donations (other than cash and publicly traded securities), no value will be ascribed on the receipt or other form of acknowledgment. However, we will maintain internal records of such donations, and their valuation will be conducted in accordance with IRS guidelines and accounting standards for nonprofit organizations, involving independent appraisers for significant assets when necessary.

Risk Management

We recognize that fundraising involves certain risks and actively work to minimize them.

Identified Risks

• Fraud: The risk of receiving funds from illicit sources or the misuse of funds within the organization.
• Non-compliance: The risk of failing to comply with federal (IRS) and state (Delaware) laws regarding fundraising and financial reporting.
• Negative Reputation: The risk of reputational damage due to unethical practices, misuse of funds, or association with undesirable sources.
• Conditional Donations: The risk of accepting donations with conditions that may conflict with the organization’s mission or create unforeseen obligations.

Risk Mitigation Plans

• Donor Source Verification: We will carefully vet the sources of all donations. If we become aware that the source of a donation is linked to criminal activity, we are obligated to decline or return it.
• Transparency of Conditions: If a donation comes with conditions, the Board of Directors will make the decision whether to accept or decline it. We will evaluate whether the conditions align with the organization’s mission and do not create unreasonable obligations or risks.
• Strict Legal Compliance: The Director of Compliance will oversee adherence to all federal and state requirements, including Form 990 filing and disclosure rules.
• Internal Controls and Audit: Regular internal audits and stringent financial control procedures will help prevent and detect misuse of funds.
• Code of Ethics: Maintaining high ethical standards in fundraising and all organizational activities.
• Reputation Management: Actively and transparently engaging with donors and the public to maintain a positive reputation.

Summary and Contact

This Fundraising Policy provides a framework for our activities and helps us effectively and ethically raise funds to fulfill our mission. We are always ready to answer any questions regarding our fundraising practices.

For questions regarding our Fundraising Policy, contact:

Brain Drain Unlimited Foundation
8 The Green, Suite 8426
Dover, DE 19901

info@braindrainfoundation.org
+1 (302) 554-7211

We reserve the right to modify this Fundraising Policy at any time. Any changes will be effective immediately upon posting on our website. We encourage you to review this disclaimer periodically for any changes.

Last Updated: June 14, 2025
Last Revised: June 14, 2025