AML/KYC Policy

This AML/KYC Policy (hereinafter — the "Policy") has been developed by RBY Commerce Ltd. (hereinafter — the "Company", "MulenPay") in order to prevent the use of the Company services for:

• legalization (laundering) of proceeds of crime;
• financing of terrorism;
• financing of the proliferation of weapons of mass destruction;
• fraudulent activity;
• circumvention of international sanctions;
• other unlawful transactions.

The Company adheres to a risk-based approach and applies customer verification and transaction monitoring procedures in accordance with international compliance standards.

This Policy applies to:

• users of the Site;
• clients of the Company;
• merchants;
• partners;
• representatives of legal entities;
• persons acting on behalf of clients.

The Company is guided by the following principles:

• customer identification;
• verification of the accuracy of the information provided;
• a risk-based approach;
• ongoing monitoring of client activity;
• detection of suspicious transactions;
• compliance with sanctions requirements;
• cooperation with competent authorities within the framework of the law.

The Company has the right to carry out customer identification and verification procedures before the provision of services begins or at any moment of cooperation.

As part of the verification, the following may be requested:

Each client may be assigned a risk level:

For high-risk clients, additional verification measures (Enhanced Due Diligence) may be applied.

The Company screens clients against international sanctions lists, including but not limited to:

• United Nations Sanctions Lists;
• European Union Sanctions Lists;
• UK Sanctions List;
• OFAC Sanctions Lists;
• other international sanctions databases.

If sanctions risks are identified, the Company has the right to refuse service or to terminate cooperation.

The Company monitors transactions and client activity in order to detect signs of:

• fraud;
• money laundering;
• financing of terrorism;
• use of front persons;
• circumvention of sanctions;
• other suspicious actions.

The Company has the right to analyze information related to the use of the services to the extent necessary to comply with the law and to ensure security.

The Company has the right to request documents confirming the origin of funds or the economic substance of the client activity.

Such documents may include:

• bank statements;
• tax documents;
• contracts;
• invoices;
• accounting reports;
• other supporting documents.

Signs of suspicious activity may include:

• provision of false information;
• refusal to undergo verification;
• use of forged documents;
• attempts to conceal beneficial owners;
• inconsistency of transactions with the declared type of activity;
• an unusual payment structure;
• signs of fraud;
• transactions related to sanctions restrictions.

If such signs are identified, the Company has the right to:

• request additional documents;
• restrict access to the services;
• suspend service;
• terminate cooperation;
• transfer information to competent authorities in cases provided for by law.

Information obtained as part of the AML/KYC procedures is stored for the period necessary to fulfill the requirements of the law, the internal procedures of the Company and risk management.

Access to such information is granted only to authorized persons.

The Company reserves the right to refuse to provide services or to terminate service without giving reasons if:

• the client has not completed the verification procedures;
• inaccurate information has been provided;
• signs of unlawful activity have been identified;
• there are sanctions restrictions;
• further cooperation creates unacceptable risks for the Company.

Personal data obtained as part of the AML/KYC procedures is processed in accordance with the Privacy Policy of the Company.

The Company takes reasonable organizational and technical measures to protect such information from unauthorized access, alteration, disclosure or destruction.

The Company has the right to amend this Policy at any time.

The new version takes effect from the moment of its publication on the Site.

Continued use of the services after the publication of changes means the consent of the client to the updated version of the Policy.