AML/CFT Compliance

This document describes in general terms the compliance framework for the prevention of money laundering, terrorism financing and financing of the proliferation of weapons of mass destruction (AML/CFT/CPF) applied by the Ink Platform, in its capacity as a Designated Non-Financial Business and Profession (DNFBP) registered before SUGEF. The internal Prevention Manual, approved and signed by the operator in their capacity as a self-employed trader (persona física comerciante), is not published in full to preserve the effectiveness of the procedures. Its content may be examined by SUGEF and other competent Costa Rican authorities in the exercise of their powers.

1. SUGEF registration

Usure, a self-employed trader (persona física comerciante), is registered before SUGEF under article 15(d) of Law N° 7786 on Narcotic Drugs, Psychotropic Substances, Unauthorized Drugs, Related Activities, Money Laundering and Terrorism Financing, as a DNFBP that administers third-party funds to provide payment services.

2. Scope of SUGEF supervision

The registration is exclusively for AML/CFT/CPF prevention purposes. SUGEF does not supervise the businesses, products or services offered, nor their security, stability or solvency. Funds under administration are not covered by the Deposit Guarantee Fund.

3. Compliance organizational structure

The Platform has a Compliance Liaison responsible for relations with SUGEF and the Financial Intelligence Unit (UIF) of the Costa Rican Drug Institute (ICD): [COMPLIANCE LIAISON]. Their designation and contact details are reported to SUGEF under SUGEF Accord 11-18.

4. Customer Due Diligence

The Platform applies Customer Due Diligence procedures proportionate to the risk profile, under SUGEF Accord 13-19. Procedures include, among others:

• Tattoo-Artist identity verification (valid national ID, public Hacienda API lookup, IBAN validation).
• Beneficial-owner identification when the Artist operates under a legal entity.
• Screening against Politically Exposed Persons (PEP) lists, international sanctions lists (UN, OFAC) and domestic watchlists.
• Basic identification of End Clients through the conversational channel (name, verified phone).
• Periodic re-assessment of the risk profile.

5. Transaction monitoring

The Platform monitors transactions processed on its marketplace through risk-based rules (amount thresholds, frequency, countries involved, unusual patterns). Alerts are documented and, where applicable, escalated to a Suspicious Activity Report (SAR) to the UIF/ICD.

6. Document retention

Under article 16 of Law N° 7786, AML/CFT/CPF records are retained for a minimum of five (5) years from the end of the relationship or transaction.

7. Training

All staff with access to Artist, End-Client or transaction information receives mandatory annual training in AML/CFT/CPF prevention, under SUGEF Accord 13-19.

8. Internal whistleblowing channel

Any person, internal or external, may confidentially report suspected non-compliance to hola@usure.pro with subject "AML Report". The Platform protects the confidentiality of the reporter and prohibits retaliation.

9. Cooperation with authorities

The Platform cooperates fully and timely with SUGEF, the ICD/UIF, the Public Prosecutor's Office and other competent authorities within their legal powers. Formal requests are addressed within the deadlines provided by law.

10. Mandatory disclaimer

Usure is registered before SUGEF for the purposes of article 15 of Law N° 7786. This registration is exclusively for the prevention of money laundering and terrorism financing. SUGEF does not supervise the businesses, products or services offered, nor their security, stability or solvency. Funds under administration are not covered by the Deposit Guarantee Fund.

11. Language

In case of any discrepancy between the versions of this document, the Spanish version prevails.