Anti-Money-Laundering and Know-Your-Customer programme

This Notice describes the anti-money-laundering ("AML"), counter-terrorism-financing ("CTF"), and customer-due-diligence obligations that Rpagos S.R.L ("RSends") applies to all users of the Service. It is provided for transparency and forms part of our Terms of Service.

1. Compliance framework

RSends operates a risk-based compliance programme aligned with:

• The Recommendations of the Financial Action Task Force (FATF), in particular Recommendation 15 on Virtual Asset Service Providers.
• Costa Rica's AML/CFT framework, including Ley 8204 and applicable regulations issued by SUGEF and the Instituto Costarricense sobre Drogas (ICD).
• International sanctions regimes, including OFAC (United States), consolidated United Nations sanctions, and EU restrictive measures.

2. Three-level customer screening

We apply a three-level approach to customer screening:

1. Level 1 — Identity verification. Confirmation of identity using government-issued documents and a liveness check, sanctions and politically-exposed-person (PEP) screening, and basic risk scoring.
2. Level 2 — Enhanced due diligence (EDD). Triggered for higher-risk profiles (high transaction volume, exposure to high-risk jurisdictions, complex ownership structures). Requires additional documentation, including source of funds, source of wealth, and ultimate beneficial ownership records.
3. Level 3 — Continuous monitoring. Ongoing transaction monitoring against customer profiles, periodic re-verification, blockchain analytics screening of counterparties and wallet addresses, and risk-based reviews.

3. Customer Due Diligence (CDD) requirements

To open and maintain an account, you must provide:

• A valid government-issued photo identification document.
• Proof of residential address dated within the last three (3) months.
• For corporate users: certificate of incorporation, register of directors, register of shareholders, and identification of all ultimate beneficial owners holding 25% or more.
• A description of the intended use of the Service, expected transaction volumes, and counterparties.

We may request additional information at any time as part of our risk-based monitoring obligations.

4. Source of funds

For transactions exceeding applicable thresholds, or where risk indicators suggest elevated risk, we may require documentation of the source of funds and source of wealth. Acceptable evidence includes employment records, business financial statements, sale-of-asset documentation, or audited corporate accounts. We may delay or decline transactions until satisfactory evidence is provided.

5. Sanctions screening

All users, beneficial owners, and counterparties (including counterparty wallet addresses) are screened against the OFAC SDN List, EU consolidated sanctions list, UN sanctions list, and additional national lists where relevant. Lists are refreshed at least daily, and screening is repeated continuously throughout the customer lifecycle.

Transactions involving sanctioned persons, sanctioned wallet addresses, or sanctioned jurisdictions will be blocked and reported to the relevant authorities as required.

6. Suspicious-activity reporting

Where transactions or behaviour suggest possible money laundering, terrorism financing, sanctions evasion, fraud, or other financial crime, we will file an internal Suspicious Activity Report (SAR) and, where required, escalate to the Costa Rican Financial Intelligence Unit and to other competent authorities. We may not be permitted to inform you that a report has been filed ("tipping-off").

7. Record keeping

We retain customer-due-diligence records, transaction records, and AML monitoring records for a period of at least five (5) years from the end of the business relationship or from the date of the transaction, in accordance with Costa Rican regulations.

8. Customer cooperation

By using the Service you agree to:

• Provide accurate, complete, and up-to-date information.
• Respond promptly to compliance requests, including documentation requests and source-of-funds verifications.
• Notify us promptly of changes to your beneficial ownership, control, or registered address.
• Not use the Service to evade compliance controls or in connection with sanctioned activity.

Failure to cooperate may result in suspension or termination of your account and, where appropriate, reporting to authorities.

9. Risk-based approach

Our compliance programme is risk-based and proportionate. The level of due diligence, monitoring, and review applied to a relationship depends on the assessed risk, taking into account customer type, geography, products used, transaction patterns, and external risk indicators.

10. Changes to this Notice

We update this Notice from time to time as the regulatory landscape evolves. The "Last updated" date at the top of this page reflects the most recent revision.

11. Contact

Compliance enquiries: emiliocatteddu@rsends.io
Postal: Rpagos S.R.L, Compliance Office, San José, Costa Rica.