Public AML/CFT Policy

2.1. Before a seller is connected to payment acceptance, the Company verifies their identity or registration details, the authority of the representative, the ownership and effective control structure, the nature of the business and the payout details. Connection takes place after the necessary checks and approvals are completed.

2.2. For a legal entity, registration and tax details, a register extract, the address and information about the head, representatives and ultimate beneficial owners may be requested. For individual entrepreneurs and natural persons — details of identity, identity document, address and registration or tax status where they are necessary for verification.

2.3. The Company may request documents on authority, ownership structure, bank account, source of funds, purpose of the transaction, origin of the goods and the right to distribute them. For foreign documents, a translation and proper certification are requested where necessary.

2.4. Buyers are verified to the extent necessary for the respective service or transaction. Additional information may be required if the mandatory data is insufficient or the circumstances of the transaction call for clarification.

2.5. Users provide accurate and up-to-date information and report material changes to it. If a mandatory check cannot be completed, connection or execution of the respective transaction may be declined on an applicable legal or contractual basis.

3.1. The risk assessment takes into account information about the client and their business, the ownership structure, the goods, the geography of transactions and the nature of settlements. In case of elevated risk, the Company may carry out additional checks and request supporting documents.

3.2. Information about the client, representatives, beneficial owners and other parties to transactions is checked to the necessary extent against the applicable lists and available lawful sources. A possible match requires verification and does not in itself mean a violation.

3.3. The Company may re-verify information during the period of service, including when the client's data, payment details, business or the circumstances of transactions change. Non-resident status or the status of a politically exposed person does not in itself mean unlawful activity.

4.1. The seller provides an accurate description of the goods, the price, the method and terms of delivery, the terms of use, territorial restrictions and the refund terms. The seller confirms the lawful origin of the goods and the necessary rights to distribute them.

4.2. Depending on the goods, supplier documents, licence or distribution agreements, and confirmation of authorship and of the right to resell may be requested. Buying a copy of software or a subscription does not in itself confirm the right to resell them further.

4.3. Fictitious goods and orders, counterfeit goods, stolen accounts and data, cash-out transactions disguised as purchases and the acceptance of payments for undisclosed third parties are not allowed. The seller or the actual category of the goods may not be disguised. Certain categories are allowed only after the necessary legal and banking approval.

5.1. The Company analyses payments, order information, confirmations of delivery of goods, refunds, payouts and user requests in order to identify inconsistencies and prevent unlawful use of the Platform.

5.2. To clarify the circumstances of a transaction, agreements, invoices, confirmations of the order, of delivery of the goods or of provision of access, explanations of the purpose of the payment and other documents relating to the transaction may be requested. A verification request does not in itself accuse the user of a violation.

6.1. Payouts to sellers are made for confirmed sales to the verified bank account of the proper recipient within the permitted settlement arrangement. A change of payment details requires verification. The designation of a third party is not a sufficient basis for transferring funds to that party.

6.2. The settlement procedure, fees, payout terms and the permissible reserves and deferrals are determined by the respective agreement and the applicable requirements. This Policy does not in itself introduce additional fees, reserves or periods of withholding funds.

6.3. A refund is linked to the original purchase and is processed under the applicable refund rules and the rules of the bank and the payment system. A change of the recipient or the payment instrument is possible only on proper grounds and after the necessary checks.

6.4. This Policy describes settlements with sellers by bank transfer. It does not provide for cash payouts, payouts in crypto assets or the purchase of crypto assets with sellers' funds.

7.1. Where there are grounds provided for by legislation or an agreement, the Company may decline a connection or a transaction, restrict certain functions of the Platform or terminate service. Measures are applied within the Company's powers, taking into account the nature of the circumstances identified.

7.2. Suspension of transactions, blocking or freezing of funds is carried out only where there is an applicable legal basis. Suspicion itself or the filing of a report does not mean an arbitrary right to withhold funds. Mandatory restrictions are lifted under the established procedure.

7.3. The Company cooperates with the servicing banks and the competent state authorities and transfers information in the cases and to the extent provided for by law. Information about the check and the measure taken is communicated to the user to the extent that its disclosure is permitted by legislation.

8.1. Information and documents are processed for the identification and verification of clients, the performance of agreements and of the Company's obligations, transaction control, fraud prevention and the handling of requests — where there is a respective legal basis.

8.2. The Company restricts access to data to a circle of authorised persons and applies measures to protect it. The transfer of information to banks, competent authorities and engaged contractors is allowed where there are proper grounds and in compliance with the applicable data protection requirements.

8.3. Documents are retained for the periods necessary for the intended purposes and for the performance of statutory obligations. At the end of the applicable periods, the data is deleted or anonymised unless there is another lawful basis for retention. The detailed terms of processing and the rights of data subjects are determined by the Platform's personal data processing policy.

8.4. Users should not send passwords, confirmation codes, PIN codes or CVV/CVC codes of bank cards. Documents containing personal data are transferred only through an agreed secure channel. To obtain instructions for transferring documents, please contact support.

9.1. On matters of verification, document requests, the status of a transaction or a restriction, the user may contact the Platform's support service. It is recommended to state in the request the account or order identifier, the date of the transaction and a brief description of the matter.

9.2. The user may provide explanations and additional documents to clarify the data and have the decision reviewed. Requests are handled in the manner and within the time limits provided for by the applicable legislation and the respective agreement. The Company responds within the limits of the information it is entitled to disclose.

9.3. Suspicious activity, unauthorised use of an account, fictitious goods or infringement of rights may also be reported to support. Filing a request does not limit the user's right to apply to the competent authorities or a court.

10.1. The public Policy is posted on market.platio.by. When the Platform's approach or the applicable requirements change, the Company publishes the current version. A change to the Policy does not in itself change the terms of previously concluded agreements; they are changed under the procedure provided for.

10.2. This document sets out the general AML/CFT principles. Technical algorithms, internal criteria for identifying suspicious transactions and information whose disclosure is restricted by law are not included in the public version.

Operator

Platio Payment Technologies LLC

Platform

market.platio.by

Requests

support@platio.by