AML Policy

RE Platform Ltd., a St. Vincentian Company, (referred to herein as “RE PLATFORM” or “the Company”) has designed its Anti-Money Laundering and Terrorist Financing Prevention Program (referred to herein as “the Program”) pursuant to the Laws, Regulations, Codes, and Guidance Notes of Saint Vincent and the Grenadines through its relevant regulatory bodies, namely, the Financial Services Authority, the National Anti-Money Laundering Committee, and the Financial Intelligence Unit. The Program is designed to incorporate the Proceeds of Crime (Money Laundering and Prevention) Act of 2013, “the Act,” the Proceeds of Crime (Anti-Money Laundering and Terrorist Financing) Regulations of 2014, “the Regulations,” the Proceeds of Crime (Anti-Money Laundering and Terrorist Financing) Code of 2017, “the Code,” and the Anti-Terrorist Financing and Proliferation Act of 2015, and the subsequent Amendments thereof (collectively herein referred to as “the Laws”). The Program observes the FATF Recommendations as well as such recommendations that are issued by the Caribbean Financial Action Task Force from time to time.

RE PLATFORM has developed a novel token-based decentralized property listing and transfer platform where parties can transfer digital assets representing interests in profits derived from RE Platform properties or properties owned by third parties contracted by RE Platform. As such, RE PLATFORM does not specifically qualify as a Service Provider under Schedule 1 of the Act. And it is not a shell bank, sole trader, specified financial business, or the equivalent thereof, as described therein. However, in light of the novelty of RE PLATFORM’s model and commitment to prevent money laundering and terrorist financing, RE PLATFORM is a self-regulated entity, seeking to apply the letter and colour of the law to the digitized property conveyance model. This presents novel and unique challenges due to the reliance on decentralized blockchains for recording, transacting, and holding property rights.

RE PLATFORM’s business strategy is premised on becoming the standard bearer in synergizing blockchain technology with RE Platform estate. RE PLATFORM utilizes onboarding and transaction monitoring techniques to achieve unprecedented levels of transparency, reporting, and regulatory accountability. RE PLATFORM’s company core values, which are embedded into the company’s culture, are anchored by integrity, responsibility, and accountability.

To accomplish this, RE PLATFORM has designed its program to fulfill the Five Pillars of AML Compliance:

Internal Controls
Designated AML Officer
Independent Testing and audit
Comprehensive Training of Relevant Team
Customer Due Diligence to determine Beneficial Ownership

The Program is designed to ensure the highest ethical standards to protect RE PLATFORM’ safety and soundness and to promote integrity within the Vincentian financial system. It is designed to facilitate effective risk management in the form of identification, assessment, and internal controls to monitor suspicious customer activity. RE PLATFORM utilizes virtual currency related technologies, including database tools and information retrieval mechanisms, to counter terrorist financing and money laundering risks by closely surveilling customer activity and selectively screening new customers. To this end, the Program is designed to;

Provide advice to the business development, sale, and support team regarding the law, regulations, and codes relating to AML/CFT
Monitor existing and proposed AML and sanctions rules and regulations regularly, and to ensure that RE PLATFORM is in compliance with all relevant laws, regulations, and codes;
Ensure that RE PLATFORM can anticipate regulatory changes and maintain the highest standard of AML policy and procedures;
Perform compliance monitoring reviews on a risk basis;
Identify any weaknesses in RE PLATFORM’s AML Program and report any such deficiencies to Senior Management;
Review, analyze, and approve RE PLATFORM’s AML and sanctions rules and regulations;
Review and analyze customer due diligence (“CDD”) information for all high risk customers with an emphasis on fulfilling ultimate beneficial ownership (UBO) requirements and a randomly selected sample of medium and/or low risk customers;
Identify and investigate suspicious activity;
File Suspicious Activity Reports (“SARs”) as requested using the required templates designed by the FIU;
Provide regular departmental reporting to the Chief Executive Officer;
Educate employees about applicable AML/CFT laws, regulations, and codes.

1.0 Money Laundering & Terrorist Financing

Money laundering is defined as the process intended to mask benefits derived from serious criminal offenses or criminal conduct to make it appear that such benefits originated from a legitimate source.

Money laundering is committed by any person who, knowing that any monetary instrument or property represents, involves, or relates to the proceeds of any unlawful activity:

transacts said monetary instrument or property;
converts, transfers, disposes of, moves, acquires, possesses or uses said
monetary instrument or property;
conceals or disguises the true nature, source, location, disposition, movement or ownership of or rights with respect to said monetary instrument or property;
attempts or conspires to commit money laundering offenses referred to in
Items (1),(2) or (3) above;
aids, abets, assists in or counsels the commission of the money laundering offenses referred to in items (1), (2) or (3) above; and
performs or fails to perform any act as a result of which he facilitates the
offense of money laundering referred to in items (1) (2) or (3) above.

Money laundering is also committed by any service provider who knowing that a suspicious transaction is required to be reported to the proper authorities but fails to do so.

1.1 The Three Stages of Money Laundering

Generally, money laundering is composed of three (3) stages involving several transactions which could alert an intermediary such as RE PLATFORM to the money laundering activity:

Placement – the act of disposing of the proceeds drawn from illegal activities into the formal financial system
Layering – the act of separating illicit proceeds from their source by creating complex tiers of financial transactions in order to disguise the audit trail and to provide anonymity
Integration – the act of providing an appearance of legitimacy to criminally- derived wealth. If the layering process is successful, the integration step places the laundered proceeds back into the economy in a manner that their re-entry into the financial system with an appearance of being normal business funds

1.2 Basic Principles to Combat Money Laundering

RE PLATFORM endeavors to apply the following principles in order to detect, prevent and oppose the use of the Company’s services for money laundering and terrorist financing

1.2.2 Know Your Client

RE PLATFORM obtains satisfactory evidence of the client’s identity, and endeavors, to the best of its abilities, to put in place effective procedures for verifying the bona fide purposes of persons who may deal, transact, or apply for, business with the Company.

1.2.3 Compliance with Laws

RE PLATFORM ensures that its business is conducted in conformity with high ethical standards, that laws and regulations are respected and complied with whenever possible, and that service is not provided where there is good reason to believe that transactions are associated with money laundering, terrorist financing, or proliferation activities.

1.2.4 Cooperation with Law Enforcement Agencies

Within the legal constraints relative to client confidentiality, RE PLATFORM cooperates with law enforcement agencies. This includes taking appropriate measures within the law if there are reasonable grounds for suspecting money laundering. Any disclosure made in conjunction with the Act shall be made to the Saint Vincent and the Grenadines Financial Services Authority, the Royal Saint Vincent and the Grenadines Police Force, or an appropriate financial regulatory body.

1.2.5. Policies, procedures and training.

RE PLATFORM adopts policies consistent with the principles set out in relevant laws, regulations and codes, and ensures that its staff are informed of such policies and adequately trained in matters service provider herein. To promote adherence to these principles, RE PLATFORM utilizes decentralized blockchain technology for client identification, record keeping and retention of transaction activity and the reporting of service provider and suspicious transactions. RE PLATFORM ensures that its team is fully trained in understanding this technology and capable of maintaining and utilizing blockchain records for compliance purposes.

2.0 RE PLATFORM Compliance Function

RE PLATFORM's Compliance program is tasked with ensuring the company’s adherence to regulatory standards and ongoing legal obligations. The Compliance Office maintains a direct line of communication with and responsibility under the Board of Directors. For its part, the Board of Directors is the company’s primary responsible party and must review and formally approve of any policies and procedures, including those related to the Laws, and all changes thereto. The Compliance Office, in turn, reports to the Board of Directors on compliance related matters, including SAR filings, compliance reports, and relevant transaction data.

In pursuit of the standards set out by the Board of Directors, the Compliance Office seeks to create a culture of compliance company wide. This is accomplished through embedding compliance functions into company processes, through administering regular compliance trainings and education sessions, and by requiring compliance clearance for key executive and interdepartmental decision-making.

2.1 Departmental Structure

RE PLATFORM's Compliance Office is responsible for overseeing the day-to-day management of The Program. The Department is managed by the company’s AML/CFT Compliance Officer, “Compliance Officer,” (who shall also act as the AML/CFT Reporting Officer). The Compliance Officer has the following principle functions:

Oversee and monitor the compliance of RE PLATFORM with the Laws, all legislation for the time being in force concerning money laundering and terrorist financing;
Receive and consider internal money laundering and terrorist financing disclosures;
Consider whether a suspicious activity report should be made to the Financial Intelligence Unit;
Where he or she considers a suspicious activity report should be made, submit the report to the FIU;
Organizing the timing and contents of AML training of officers and employees.

2.2 Internal Audit and Regulatory Audits

RE PLATFORM conducts internal audits to ensure that it is meeting the standards laid out in its policies and procedures. The Audit Committee, consisting of senior staff independent of the Compliance Office, evaluates a sample of Compliance Office activities, including customer due diligence record collection, maintenance, and client decisioning.

All findings and recommendations shall be promptly communicated to the Compliance Office and shared with the Board of Directors. The Compliance Office shall be responsible for the drafting, presentation, and implementation of the strategy to address any and all deficiencies and recommendations, and shall liaise with Senior Management in a timely manner to facilitate the implementation. All findings shall be resolved prior to the next scheduled Audit, or at a time period as agreed upon by the parties.

Should the Company be subject to an audit by a regulator, the Compliance Office shall ensure that all requests for information are timely responded to and handled in a responsible manner. Any findings, comments and recommendations shall be assessed and resolved within an agreed timeframe. Frequent updates as to the implementation progress shall be communicated to the auditing party as required.

2.3 Risk Assessment

RE PLATFORM identifies, reviews and assesses its money laundering and terrorist financing risks arising from customers, products, delivery lines or countries of operations. The risk assessment examines relevant risk factors related to RE PLATFORM's various business areas and document its results and findings. The Annual Risk Assessment is designed to:

Identify any gaps and/or opportunities for the improvement in AML policies, processes and procedures;
Assist in making informed decisions regarding risk appetite and the implementation of control efforts and resource allocation;
Provide management with an improved understanding how each business units AML policies and procedures align with its risk profile;
Enhance and improve risk mitigation strategies including internal controls designed to reduce residual risk exposure
Make management aware of key risks, control gaps and remediation efforts
Document key risks, remediation efforts, and potential control gaps, where needed, to ensure that this information can be provided to relevant third parties.
Provide management with guidance to ensure that resources and priorities are aligned with company risks

2.4 Product Risk Assessment

RE PLATFORM conducts a risk assessment prior to launching new products or lines of business. The Compliance Office, in conjunction with other departments, reviews and assesses risks related to any new delivery mechanisms involved in the development of new products and new business practices. This risk assessment also covers the use or development of new or existing technologies for new products or those currently in use.

2.5 Training and HR Policies

The administration of the Program shall rely on both proactive and reactive measures among its employees.

RE PLATFORM provides ongoing and proactive education and training for its staff and personnel, including directors and officers, to ensure that they are aware of their personal obligations and responsibilities in preventing money laundering and to be familiar with its system of reporting and investigating suspicious matters. The training materials focus on the company’s obligations to identify customers, retain documents, detect and report suspicious activity, understand and comport with internal procedures, and follow the chain of command in reporting and investigating customer activity. Training materials are recorded, and attendance of mandatory trainings are maintained in company records.

The administration of the AMLTFR Program shall rely on both proactive and reactive measures among its employees. Continuing education and training on anti-money laundering laws, regulations, codes, policies and procedures, are provided to new and existing staff and associates

New staff are provided with an introduction and background of money laundering and terrorist financing detection and prevention, identification of suspicious transactions, and reporting procedures.

Employees who deal with the clients or transactions directly have first point of direct contact with potential money launderers. Their efforts are vital to RE PLATFORM's reporting of such transactions. Training in identifying suspicious activity and on the procedure to be adopted when a transaction is deemed to be suspicious is be provided at training sessions. The frontline staff are made aware of RE PLATFORM's policy for non-regular clients particularly where dealing with large cash transactions are involved, if any. The need for extra vigilance in cases under suspicious circumstances shall also be emphasized.

Managers are given a higher level of instruction covering the various aspects of money laundering. This includes the offenses and penalties arising from the Act, procedures relating to service of production and restraint orders, internal reporting procedures, requirements for verification of identity, and the retention of records.

RE PLATFORM makes arrangements for refresher training to remind officers, directors, compliance personnel, and key employees of their responsibilities and to make them aware of changes in the laws and rules relating to money laundering, as well as its internal policies and procedures.

The Company shall make sure that there are internal controls and HR-administered policies to address employee’s behaviour (acts/omissions) which are not in compliance with the Program. Such incidents should be recorded. Third confirmed incident of any acts or omissions by any staff shall trigger the employee’s performance review and may result in termination.

3.0 Customer Due Diligence

RE PLATFORM adopts a risk-sensitive basis for customer due diligence, with “Know-Your-Customer” (KYC) information collected on every customer and heightened disclosure requirements and scrutiny place on higher risk customers. RE PLATFORM maintains internal procedures for identifying and verifying customer identities and conducting enhanced due diligence. Together, these procedures ensure that information is being collected and screened on customers to prevent the use of RE PLATFORM's system by individuals or groups involved in money laundering, terrorist financing, proliferation, or other illicit activities.

3.1 Record-keeping and Document Updates

Documents submitted by customers are maintained and stored in a secure environment. They shall be stored for as long as a RE PLATFORM account remains active. Responsibility for recordkeeping lies with the CEO and CTO of the company.

Having established the true and identity of its customers, the Company shall carry out an update of all its customers information no later once 3 years non-high risk customers. Customers identified as high risk shall be subject customer document updates at least once per year, or as deemed necessary in a shorter period by the Compliance Officer.

Documents submitted by the customer at renewal are subject to the same scrutiny and verification processes as during initial screening.

All transaction documents and records are stored indefinitely. Given the company’s reliance on blockchain technology, these type of records can be relied upon and maintained indefinitely.

The Company shall maintain and safely store all records of customer identification, and transaction documents for at least seven (7) years from the date the account was closed. Or the FIU may, by written notice, specify a period longer than 7 tears for any specified customer.

3.2 Customer Due Diligence (CDD)

Customers subject to RE PLATFORM's Customer Due Diligence Program must pass the company’s strict Know-Your-Customer (“KYC”) customer identity verification process. This includes rigorous screening of customer provided documentation to verify its authenticity, veracity and accuracy.

3.2.1 New Individual Customers (CDD)

RE PLATFORM's customers are subject to standard customer due diligence at account opening. This process includes obtaining documents from customers to verify customer information which can include the following documents or information, and disclosures:

Name of customer;
Date and place of birth;
present address;
nationality;
nature of work and source of funds of beneficial owner
Contact number or information;
name of employer or nature of self-employment/ business;
Source of funds;
Visual verification; and/or
Tax identification number (TIN);
Social Security System number

RE PLATFORM accepts documents issued by any of the following official authority:

Government documents including its political subdivisions, agencies, and instrumentalities;
Service providers registered with and supervised or regulated by competent local or foreign regulators; and
Passports

3.2.2 New Corporate Customers

RE PLATFORM's Corporate customers are subject to standard customer due diligence at account opening. This process includes obtaining documents from customers to verify corporate customer information which can include the following documents, information, and disclosures:

Name of entity;
Name, present address, date and place of birth, nationality, nature of work and source of funds of beneficiary owner or beneficiary, if applicable, and authorized signatories;
Official address;
Contact numbers or information;
Nature of business;
Specimen signatures or biometrics of the authorized signatory
secondary license or certificate of authority issued by the supervising authority or other government agency;
Articles of Incorporation/partnership;
Latest General Information sheet which lists the names of directors/trustees/partners, principal stockholders owning at least twenty percent (20% of the outstanding capital stock and primary officers such as the president and Treasurer);
Board or Partners' resolution duly certified by the corporate/ Partners' secretary, or other equivalent document, authorizing the signatory to sign on behalf of the entity.

3.4.4 Third party reliance

RE PLATFORM may rely on identification processing and/or gathering of minimum information and face-to-face contact undertaken by a third party subject to the following:

RE PLATFORM obtains written sworn certification to the effect that the third party has conducted prescribed customer identification procedures in accordance with international norms regarding AML compliance, designed to establish the existence of the ultimate customer, and has in its custody all of the minimum information and/or documents required to be obtained from the customer; and
RE PLATFORM has the ability to obtain identification documents from the third party upon request without significant delay;

4.0 Enhanced Due Diligence (EDD)

Customers are subject to Enhanced Due Diligence (“EDD”) and heightened scrutiny when they pose heightened AML/CFT risk. Customers are considered high risk when, during the process of conducting customer due diligence, suspicious activity is detected and the customer is classified as high risk during due diligence screening. Customers assessed to be high risk may be required to disclose additional documents or otherwise demonstrate the validity of their identifying information, and to provide further documents to the Company so it may gain a greater understanding of the customer risk profile.

4.1 Enhanced Due Diligence Screening

Enhanced Due Diligence Screening forms the backbone of the EDD process and requires the collection of additional customer information and/or identification documents beyond the standard due diligence requirements.

RE PLATFORM Compliance personnel should carry out due diligence when suspicious activity occurs, such as:

Signing up with fraudulent documents or false identities;
Receiving reports on customers having committed a crime with a financial component;
Customers who are politically exposed or are potentially in violation of sanctions or international law;
Knowing that a customer was or is engaged or engaging in any unlawful activity as specified above.

If RE PLATFORM is unable or fails to satisfactorily complete the enhanced due diligence procedures, or reasonably believes that performing the enhanced due diligence process will tip-off the customer, it shall report the activity to the relevant regulator or law enforcement authority, regard the user as “High Risk”, and closely monitor the account and review the business relationship. If RE PLATFORM is precluded from identifying the customer, then the Company shall decline to continue offering services to such customers.

EDD may include querying customers, requesting documentation to verify a customer identity, or analyzing customer behavior to detect, confirm, or investigate prospective illicit activity or other wrongdoing. Customers can be queried on a range of issues including the use of their account, whether it has a business or personal purpose, and how the intended use the account is expected to pattern in future transactions. Customers may also be questioned as to the owners and users of the account. In some instances customers are required to disclose users of the account and whether or not they act or have acted as an intermediary or on behalf of other customers. New customers disservice provider in this process may be required to follow customer due diligence processes, and required to list the companies of which they are a principal and other relevant information available through public databases or over the internet.

Customers subject to EDD screening may be required to disclose the source of the funds in their account and to account for where they derive their income. Such customers may also be required to disclose commercial bank where they maintain accounts. Additional information, such as estimates for their anticipated transaction volumes, may also be requested.

Senior management approval shall be secured to commence or continue business
relationship/transacting with the customer if an investigation concludes that this is a high risk customer who poses substantial risk to the company’s compliance program and its capacity to maintain its AML/CFT compliance standards. This includes conducting enhanced ongoing monitoring of the business relationship, by measures including but not limited to:

increasing the number of timing controls applied to the customer’s account;
selecting patterns of transactions that need further examination;
Requiring the first payment to be carried out through an account in the customer's name with a bank subject to similar CDD standards as the Company, where applicable; and
Perform such other measures as the service provider may deem reasonable or necessary

In cases where pertinent and necessary information cannot be obtained, or any information or document provided is false or falsified, or result of the validation process is unsatisfactory, RE PLATFORM shall deny a business relationship with the customer without prejudice to the reporting of a suspicious transaction to the appropriate regulatory body when circumstances warrant.

4.2 Non-discrimination

Although RE PLATFORM raises the risk profile of high risk customers, it does not prohibit their use of RE PLATFORM services in a discriminatory way. RE PLATFORM seeks to ensure that, in pursuit of its goal of detecting and preventing money laundering and terrorist financing, and applying the Program to its organizational model, it does not discriminate against:

Politically Exposed Persons (PEPs), their immediate family members or close associates
Individuals of any specific religion, race or ethnic origin, or such other attributes or profiles

4.2.1 Documentary Requirements (Individual Customers)

High Risk Individual Customers may be prompted to disclose two or more of the following documents as part of EDD Screening:

Individual income tax returns with tax authority acknowledgement;
Bank statements from accredited financial institution verifying salary and/or source of funds details; and/or
Other documentation from a trusted third party verifying salary and/or source of funds

Individual disclosures may be verified using methods including:

Confirming the date of birth from a duly authenticated official document;
Verifying the address through evaluation of utility bills, bank or credit card statement, sending thank you letters, or other documents showing address or through on-site visitation;
Contacting the customer by phone or email;
Determining the authenticity of the identification documents through validation of its issuance by requesting a certification from the issuing authority or by any other effective and reliable means; and/or
Determining the veracity of the declared source of funds

4.2.2 Documentary Requirements (Corporate Customers)

Customers subject to enhanced due diligence may be periodically reassessed with requests for information updates. Whenever possible, this information is validated by accredited third parties to ascertain its authenticity. Corporate customers subject to EDD screening may be required to furnish information in some or all of the following categories:

Prior or existing bank references;
The name, present address, nationality, date of birth, nature of work, contact number and source of funds of each of the primary officers (e.g. President, Treasurer);
Volume of assets, other information available through public databases or internet and supporting information on the intended nature of the business relationship, source of funds or source of wealth of the customer (Taxation Return, Audited Financial statement, Loan Application, Deed of sale, etc.); and
Reasons for intended or performed transactions.

Corporate Disclosures are verified using methods including:

1. Validating source of funds or source of wealth from reliable documents such as audited financial statements, taxation returns, bank references, etc.;
2. Inquiring from the supervising authority the status of the entity;
3. verifying the address through on-site visitation of the company, sending thank you letters, or other documents showing address; and/or
4. Contacting the entity by phone or email.

4.2.3 Politically exposed persons (PEP)

RE PLATFORM applies enhanced due diligence to customers it has established are a Politically Exposed Person (PEP). PEP means:

A foreign politically exposed person
A domestic politically exposed person
A person who is, or has been, entrusted with a prominent function by an international organisation.

RE PLATFORM’s PEP policy also includes immediate family members:

A spouse
A partner (as defined in the Act)
Children and their spouses or partners
Parents
Grandparents and grandchildren
Siblings

Those with close relationships to a PEP, and associates that are reputedly known to have:

Any person known to maintain a close business relationship with that person or to be in a position to conduct substantial financial transactions on behalf of the person
Any person who is known to have join beneficial ownership of a legal person or legal arrangement, or any other close business relationships, with that person, and
Any person who sole beneficial ownership of a legal entity or legal arrangement that is known to exist for the benefit of the main/principal PEP.

RE PLATFORM endeavors to collect and maintain record of the true and full identity of PEPs, as weil as their immediate family members, close associated, and entities related to them.

RE PLATFORM also adopts the following risk management systems to determine whether a customer or the beneficial owner is a PEP; it shall obtain senior management approval before establishing, or continuing, for existing customers, such business relationship; RE PLATFORM shall also take reasonable measures to establish the source of wealth and the
source of funds of customers and beneficial owners identified as PEPs; and conduct enhanced ongoing monitoring on that relationship.

5.0 Sancioned, Prohibited, and Restricted Users

5.1 Sanctions Screening

The Company does not accept customers from certain sanctioned and high risk jurisdictions, nor does it accept any OFAC sanctioned individuals. Customer suspected to be a positive match against those lists shall be subject to enhanced scrutiny and EDD and further verified. Should a match be confirmed, such customers’ activity and transactions will be escalated to Senior Management and to the Board.

To this end, please see list below for prohibited countries:

State of Libya
Republic of India
Islamic Republic of Iran
United States of America
Republic of the Union of Myanmar
Republic of the Sudan
Kingdom of Cambodia
People’s Democratic of the Congo
People’s Republic of China
Singapore
Republic of Iraq
Federal Republic of Somalia
Republic of Yemen
Syrian Arab Republic
Russian Federation
Democratic People’s Republic of Korea

5.2 Shell Company Policy

RE PLATFORM applies enhanced due diligence to high risk customers, including corporate customers which it cannot confirm are actively engaged in activities in the countries in which they are formed and registered. Shell Companies of all kinds are strictly prohibited from using RE PLATFORM's services.

5.3 Bearer Shares Entities

RE PLATFORM seeks to prohibit bearer share entities, and any other entity for which the identity of beneficial owners are not known and in which ownership stakes are freely alienable.

5.4 Other Prohibited Accounts

RE PLATFORM shall ensure that its customers maintain accounts only in the true and full name of the account owner. The company reserves the right to reject or terminate an account which does not meet the above criteria, including, anonymous accounts, accounts under fictitious names, numbered checking accounts, inter alia, which shall be prohibited.

8.0 Anti-Fraud Program

RE PLATFORM remains vigilant against the threat of improper use of its system and services by groups and individuals seeking to to commit fraud. RE PLATFORM is concerned not only with its obligations under the law to prevent the use of its services by such bad actors, but also to ensuring that its customers can use RE PLATFORM services without fear of scams, frauds, and financial predators.

RE PLATFORM avoids allowing frauds and schemes to take advantage of its platform whenever possible. These threats may occur on RE PLATFORM’s platform due to its decentralized nature and tokenized platform which can allow for more diffuse ownership than traditionally possible in the traditional RE Platform estate markets. These include:

Pyramid Schemes;
Ponzi Schemes;
Telemarketing Fraud;
Nigerian Letter or “419” Fraud;
Identity Theft;
Advance Fee Schemes;
Prime Bank Note Fraud.

8.1 Notification

RE PLATFORM's Terms of Service, listed at the www.RE PLATFORM.markets website as the “User Agreement” explicitly informs customers of improper uses of its systems. Customers are notified that they cannot use RE PLATFORM's system to violate any law, regulation or code and that they are strictly prohibited from attempting to defraud RE PLATFORM or other RE PLATFORM users.

Moreover, customers are informed in the User Agreement that they may not infringe RE PLATFORM’s or any third party's copyright, patent, trademark, or intellectual property rights, provide false, inaccurate or misleading information, or take any action that imposes an unreasonable or disproportionately large load on our infrastructure (e.g. DDOS attack). Users in violation of these terms are reported and their account terminated.

8.2 Fraud Detection, Prevention, & Actioning

Fraud and other suspicious activities can be detected by many means, including reporting from customers and third parties, and negative news and social media screening processes. Instances of suspicious activity detection are forwarded to the Compliance Office and decisioned by the Compliance Officer.

9.0 Conclusion

RE PLATFORM uses its financial controls to constrict exposure to bad actors, and loosens these controls on customers whose identities have been verified and whose risk profiles have been properly gauged. RE PLATFORM’s compliance program is designed to put pressure and scrutiny on customer activity based on money laundering and terrorist finance risk profiling. RE PLATFORM's systems are designed using the most suitable and targeted techniques and technologies to ensure the company is accomplishing its compliance goals without needlessly burdening its customers. RE PLATFORM is proud of its commitment to promoting security and lawfulness within the jurisdiction of Saint Vincent and the Grenadines.

Real State

RE Platform Anti-Money Laundering Policy

Table of contents

Executive Summary