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AML-CFT POLICY

Anti-Money Laundering and Countering the Financing of Terrorism Policy

Last Updated on July 14, 2022

This Anti-Money Laundering and Countering the Financing of Terrorism Policy (“Policy”) is for Digital Collectibles Pte. Ltd. and its subsidiaries (“Rario”/“we / our / us”, which term shall refer to and include its shareholders, subsidiaries and affiliated companies, directors, investors, employees, officers, representatives, affiliates, or other related parties).

This Policy governs the access, interaction and/or use by the user(“you” or “your”), a natural person, of application, website content, products and all services related to monetary transactions (in fiat) on Rario and its applications and web platforms (i.e., Rario.com) (“Services”) made available by Rario through third party service providers (“Collaborators”) for the purpose of buying, selling and withdrawing on Rario.com.

PLEASE READ THIS POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICES. IN ADDITION TO THIS POLICY, YOU MUST COMPLY AND BE BOUND BY THE POLICIES AND PROCEDURES OF RARIO.COM AT ALL TIMES, AND ANY INSTANCE OF NON-COMPLIANCE WILL RESULT IN THE TERMINATION OF YOUR ACCOUNT ON THE RARIO PLATFORMS, AND IN APPROPRIATE REPORTING OF THE CIRCUMSTANCES OF SUCH NON-COMPLIANCE AND SUCH TERMINATION TO THE RELEVANT STATUTORY AUTHORITIES.

IMPORTANT INFORMATION ABOUT PROCEDURES — To help fight the unlawful funding of terrorism and money laundering activities, relevant governments and applicable laws around the globe require all financial institutions to obtain, verify, and record information that identifies each person who transacts on our platform. What this means for you: When you transact with Rario, we, along with our Collaborators, will ask for your name, address, date of birth, and other such information that will allow us to identify you. We may also ask for a copy of your driver’s license, Aadhaar card, passport or other identifying documents to confirm your nationality and residence (“Personal Information”).


INTRODUCTION

 

  1. At Rario, we are committed to conducting our businesses and operations in the most honest, integrated and ethical manner. Rario strongly condemns any and all activities relating to terrorism, money laundering financial transaction, and all other unlawful activities. We provide our full cooperation and support to all relevant government and regulatory authorities in order to identify, monitor, or report any such transaction.


  1. We have a zero-tolerance approach to money laundering, terrorism financing and all other unlawful activities. We are committed to acting professionally, transparently and fairly with integrity in all our business dealings and relationships as well as implementing and enforcing effective systems to counter money laundering and terrorism financing.


  1. This Policy sets out the minimum standard that must be followed. Where local laws, regulations or rules impose a higher standard, that higher standard must be followed. 


  1. Relationship: Your access and use of the Services constitute your agreement to be bound by this Policy. If you do not agree to this Policy, you must immediately stop accessing our platform or using our Services. This Policy expressly supersede prior agreements or arrangements with you with regard to the Services. Rario reserves the right to immediately terminate any Services with respect to you, or generally cease offering or deny access to the Services or any portion thereof, at any time for alleged, suspected or actual violation of this Policy. Supplemental terms may apply to certain part of the Services, such as policies for a particular event, activity or promotion, and such supplemental terms will be disclosed to you in connection with the applicable Services. Supplemental terms are in addition to, and shall be deemed a part of the terms of usage for the purposes of the applicable Services. Supplemental terms shall prevail over this Policy in the event of a conflict with respect to the applicable Services. 


  1. Amendment: Rario may amend the Policy from time to time. Amendments will be effective upon Rario posting of such updated Policy at this location or the amended policies or supplemental terms on the applicable Service or by sending an email to you. Your continued access or use of the Services after such amendments constitutes your consent to be bound by the Policy, as amended.


  1. Operational Information Collection and Sharing: Based on your proposed activities on the Rario, including without limitation, (i) funding your account, (ii) details pertaining to transactions conducted through Rario.com; (iii) completion of your KYC (as per the ‘Know Your Customer requirements set under statutory requirements), (iv) accessing of third party payment services (“Operational Information”), you may provide additional Personal Information, which may include without limitation, certain sensitive Personal Information. At all times, you agree to share the Operational Information, with such Collaborators, as may be required to adequately provide you with the Services. Any information and documentation you provide must be correct and up to date. Rario reserves the right to require additional information at any time to verify your identification and any further information that may be required to satisfy this Policy and applicable regulations. If we suspect that the information or documentation you have provided is incorrect, false, outdated or does not correspond to the conditions established in this Policy or you fail to pass the verification by your own initiative or otherwise, then in our sole discretion, we may either request you to provide the information or suspend your account till correct and up to date information and documents are provided. 


  1. Retention of Operational Information: You understand that all Operational Information may be required to be stored for statutory purposes with Rario and/or its Collaborators to help the relevant governments and statutory organizations fight the funding of terrorism and money laundering activities. Given the extremely sensitive nature of the Operational Information, you undertake that any information shared by you shall be true and accurate at all times, and any deviation from such accuracy and truthfulness of the Operational Information shall be intimated to Rario. Rario reserves the right to restrain you from conducting any activities on Rario based on the Operational Information at any time, without notice.


  1. Data Collection, Privacy and Usage: The policy for our collection and use of personal information in connection with the Services and Rario’s Privacy Policy is located at https://rario.com/privacy-policy. 


  1. Rario may additionally provide to a claim’s processor or an insurer any necessary information (including your contact information) if there is a complaint, dispute or conflict, which may include theft, involving you and a Collaborator (including our payments partners, etc.) and such information or data is necessary to resolve the complaint, dispute or conflict.

ANTI MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM (“AML/CFT”)

  1. Rario and Collaborators shall ensure that no transaction in which Rario is engaged shall be in non-compliance with jurisdictional AML/CFT related applicable laws, play active role in identification and assessment of potentially suspicious transaction, and ensure that Rario discharges its legal obligation to report suspicious transactions to concerned authorities.  


  1. Rario and Collaborators shall ensure that any AML/CFT related violations by users that may implicate Rario shall be reported immediately on discovery.  

KNOW YOUR CUSTOMER (“KYC”) COLLECTIONS

  1. You may be subject to KYC in order to successfully conduct transactions on Rario.com/Rario platforms. The requirement of KYC is in accordance with the applicable statutes and ‘you’, a customer is required to complete KYC if you want to have a closed loop wallet, i.e., without ability to withdraw, that reaches a specified threshold as per Rario’s internal systems. 

 

  1. KYC is required prior to the account being opened. In the case of “closed loop” customers reaching thresholds, KYC is required prior to the customer being granted access to the funds that caused the account to reach the threshold.


  1. Rario may on a risk-basis, subject additional customers to KYC, or require Collaborators to conduct additional KYC on its behalf. Each such Collaborator will contract with Rario conforming with Rario’s requirements, statutory requirements, and this Policy.


  1. KYC For Individuals: You must provide the following for completion of KYC, i.e., (i) full legal name; (ii) date of birth; (iii) residential address; and (iv) identification number. This must be verified through documentation (tax filings or passport) or such other document as may be acceptable to Rario as per its internal policies and regulatory requirements.


  1. Verification: Documentary verification is performed when you submit an identification document (“ID”), along with a “selfie” to evidence that you are the same individual as listed on the ID. The ID must be government issued, unexpired, list the holders nationality or residence, bear a photograph or similar safeguard, show information in English. In case you fail to pass the verification procedure, Rario is obliged to cancel the Services following the Policy.


  1. Additionally, Rario may, on a risk-basis, require a Collaborator to conduct additional KYC.


PROHIBITIONS

  1. Your activities may be prohibited, account may be suspended and Services may be restricted if Rario has knowledge or suspicion that you are involved in transactions related to:

  • Weapons of any kind, including but not limited to firearms, ammunition, knives, explosives, or related accessories;

  • Controlled substances, including but not limited to narcotics, prescription drugs, steroids, or related paraphernalia or accessories;

  • Prostitution;

  • Unlawful gambling activities including but not limited to sports betting, casino games, horse racing, dog racing, lotteries, games of chance, sweepstakes, games of skill that may be classified as gambling (i.e., poker), or other activities that facilitate any of the foregoing;

  • Money-laundering or terrorist financing;

  • Any sort of Ponzi scheme, pyramid scheme, or multi-level marketing program;

  • Goods or services that infringe or violate any copyright, trademark, or proprietary rights under the applicable law;

  • Lottery contracts, layaway systems, or annuities;

  • Counterfeit goods, including but not limited to fake or “novelty” IDs;

  • Wash trading, front-running, insider trading, market manipulation or other forms of market-based fraud or deceit;

  • Purchasing goods of any type from Tor hidden service markets or “Darknet” markets, or any other service or website that acts as a marketplace for illegal goods (even though such marketplace might also sell legal goods);

  • Transactions involving sanctioned parties, countries or coins; and

  • Any other activity that is against the laws and regulations of countries in which Rario or its Collaborators operates.


  1. You are prohibited from accessing our Services (and your IP address will be blocked by Rario or its Collaborators) if you are from one of the following countries or any other country where Services cannot be provided by Rario due to any applicable regulation or sanctions:


  • Afghanistan

  • Angola

  • Algeria

  • Bahamas

  • Belarus

  • Bolivia

  • Botswana

  • Cambodia

  • Central African Republic (the)

  • Chad

  • China

  • Congo (the Democratic Republic of the)

  • Cuba

  • Democratic Republic of Korea

  • Guinea-Bissau

  • Iran (Islamic Republic of)

  • Iraq

  • Korea (the Democratic People's Republic of)

  • Libya

  • Mali

Myanmar

  • Russia

  • Somalia

  • South Sudan

  • Sudan (the)

  • Syrian Arab Republic

  • Uganda

  • Ukraine

  • Venezuela (Bolivarian Republic of)

  • Yemen


ADDITIONAL DOCUMENTS AND SCREENING

  1. We may conduct a due diligence prior to or after creating your account, requesting additional documents, and regularly screen you against the following sanctions list:


  • Monetary Authority of Singapore

  • Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals (“SDN”) list

  • OFAC non-SDN lists

  • European Union sanctions lists

  • United Nations sanctions lists

  • UK Her Majesty’s Treasury sanctions lists.


  1. We may further screen the transactions to and from your blockchain addresses against the sanctioned blockchain addresses released and identified either by (i) regulators and agencies across different jurisdictions; or (ii) our Collaborators. We may use a Collaborator and other third party tool for such screening. 


ACTIONS & QUESTIONS

  1. Your account may be put on freeze immediately upon (i) you operating from a prohibited jurisdictions or upon discovery of the account being associated with sanctions lists under para 1.19 or 1.20 above; or (ii) usage of any virtual private networks to access Services from prohibited jurisdictions; or (iii) any notice of suspicion of AML/CFT related or suspicious transactions received from Collaborators; or (iv) pursuant to a court order, or a request from a regulator or a request from a Collaborator; or (v) if Rario determines at its sole discretion that your account poses a security or legal risk as part of internal or external investigation; or (vi) if Rario determines at its sole discretion that you reside in or are citizens or tax residents of any state, country, territory or other jurisdiction where participation in token sales would be illegal or otherwise in violation of any applicable law (“Frozen Account”).


  1. Basis input from its Collaborators and other stakeholders, Rario shall for the Frozen Account, chose appropriate course of action including (i) regulatory reporting; (ii) intimation to its Collaborators (including to Circle at sanctions@circle.com) and regulatory reporting by them, if required; or (iii) take such action as may be required under law, including permanently freezing the account pending completion.

  

  1. Any questions on the Policy may be directed at: legal@rario.com 



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