AML & KYC Policy

1. Our commitment

We apply anti-money laundering and counter-terrorist financing (AML/CTF) measures in line with the EU AML/CTF framework and the laws of England and Wales, as applicable to our activities. Implementation of this policy is overseen by our compliance officer, who can be reached at compliance@guaranza.com.

This policy applies to all users, all Transactions and all payment methods, including cryptocurrency. It forms part of our Terms of Service.

2. Risk-based approach

We assess the money laundering and terrorist financing risks associated with each customer and Transaction and apply measures proportionate to those risks. Factors we consider include:

• the customer: individual or business, ownership structure, occupation or business activity, and politically exposed person status;
• geography: the countries of residence, incorporation, payment origin and delivery;
• the Transaction: amount, currency, category of goods or services, and the frequency and pattern of Transactions;
• the payment method, in particular cross-border transfers and cryptocurrency payments;
• any information suggesting that a Transaction lacks a clear economic purpose or is inconsistent with what we know about the customer.

Customers and Transactions assessed as higher risk are subject to enhanced due diligence and closer monitoring.

3. Customer due diligence

Our staff verify the identity of every user whose total transaction volume — as Buyer and Seller combined, over the entire life of the Account, including the Transaction in progress — exceeds USD 25,000 or its equivalent, before we confirm a payment or release a payout above this threshold. On a risk-sensitive basis we may require verification earlier, in particular for cryptocurrency payments, connections to high-risk countries or unusual activity. A member of our team will contact you through the platform or from an email address on guaranza.com with instructions. For individuals, we may ask for:

• full name, date of birth, nationality and residential address;
• a valid government-issued identity document;
• proof of address;
• information on your occupation and the purpose and intended nature of your use of the Services.

For businesses, we may additionally ask for:

• the registered name, registration number, registered address and country of incorporation;
• an extract from the commercial register or an equivalent document;
• the identity of directors and authorised representatives and evidence of their authority;
• the identity of the beneficial owners, meaning the natural persons who ultimately own or control the business, including anyone holding more than 25% of the shares or voting rights;
• a description of the business activity.

We verify the information using reliable and independent sources. We will never ask for your password. If you are unsure whether a verification request comes from us, contact support@guaranza.com before sending anything.

4. Enhanced due diligence

We apply enhanced due diligence where the risk is higher, in particular for:

• politically exposed persons (PEPs), their family members and persons known to be their close associates;
• customers or Transactions connected with high-risk third countries identified by the European Commission, or with jurisdictions identified by the Financial Action Task Force (FATF) as subject to a call for action or increased monitoring;
• large Transactions, unusually complex Transactions, and unusual patterns of Transactions that have no apparent economic or lawful purpose;
• payments or payouts in cryptocurrency.

Enhanced due diligence may include:

• information and evidence on the source of funds and, where appropriate, the source of wealth;
• for cryptocurrency, proof that you own or control the sending or receiving wallet, and screening of wallet addresses and their transaction history;
• additional information on the purpose of the Transaction and the goods or services involved;
• approval by our compliance officer before the Transaction proceeds;
• more frequent reviews of your Account.

5. Sanctions screening

We screen users and, where relevant, their beneficial owners, Counterparties and Transactions against sanctions lists, including:

• the EU consolidated list of persons, groups and entities subject to financial sanctions;
• the United Nations Security Council consolidated sanctions list;
• the UK consolidated list of financial sanctions targets;
• the lists maintained by the US Office of Foreign Assets Control (OFAC), including the Specially Designated Nationals (SDN) list.

Screening is performed at onboarding and repeated on an ongoing basis. We do not provide the Services to sanctioned persons or entities or to persons owned or controlled by them, and we do not process Transactions that would breach applicable sanctions or export control rules.

6. Ongoing monitoring

We monitor Accounts and Transactions throughout the business relationship to identify activity that is unusual or inconsistent with the information we hold. We may ask you to update your information or provide further documents at any time, for example when your details change, when the size or pattern of your Transactions changes, or when your documents expire.

7. Payments and payouts

• Payments into escrow must come from an account, card or wallet held in your own name or in the name of your business. Third-party payments may be refused or returned.
• Payouts and refunds are made only to accounts or wallets held in the recipient's own name.
• We do not accept cash.
• Payment instructions are provided only in the Deal Room of the Transaction, never by email or messenger.

8. Record keeping

We keep customer due diligence records, Transaction records, correspondence and the results of our analysis for 5 years after the end of the business relationship, or longer where required by law or requested by a competent authority. Records are stored securely, with access limited to authorised staff.

9. Reporting to the authorities

Where we know, suspect or have reasonable grounds to suspect that funds are the proceeds of criminal activity or are related to terrorist financing, we report this to the competent Financial Intelligence Unit (FIU) and cooperate with the competent authorities. We also freeze funds and take other measures where required by law, including under sanctions regulations.

10. Our right to refuse, delay or terminate

To comply with our legal obligations, we may:

• refuse to open an Account or accept a Transaction;
• delay or suspend a payment, payout or refund while checks are carried out;
• hold funds where required by law or by a competent authority;
• return funds to their source where permitted by law;
• terminate the business relationship and close the Account.

If you do not provide the information we request within a reasonable time, we may be unable to continue the business relationship. To the extent permitted by law, we are not liable for losses resulting from measures taken in good faith to comply with AML/CTF and sanctions laws.

11. No tipping-off

The law prohibits us from disclosing to a customer or any third party that a report has been or may be made to the FIU, or that an analysis or investigation is being or may be carried out. We may therefore be unable to explain the reasons for a delay, refusal or termination.

12. Training and review

Our staff receive AML/CTF and sanctions compliance training appropriate to their role. We review this policy and our risk assessment regularly and update them when laws or risks change.

13. Your obligations

You must provide accurate, complete and up-to-date information, notify us of any changes and use the Services only for lawful purposes. Providing false or forged information or documents is a serious breach of our Terms of Service and may be reported to the authorities.

14. Contact

Questions about this policy or about verification requests, and reports of suspicious activity, can be sent to our compliance team at compliance@guaranza.com.