Anti-Money Laundering and Counter-Terrorist Financing Policy

AML / CTF / KYC Policy

Effective Date: 01.05.2026

Company Name: Private Enterprise “REBOHROME”

Website: https://www.rebohrome.com

Contact Email: support@rebohrome.com

Registered / Business Address: 04050, Ukraine, Kyiv, Mykoly Murashka Street, Building 6, Apartment 90

1. Introduction

ReboHrome is committed to maintaining high standards of legal, ethical, fraud prevention, and regulatory compliance in all aspects of its business operations. This Anti-Money Laundering and Counter-Terrorist Financing Policy, also referred to as the “AML Policy,” sets out the principles, procedures, and controls adopted by ReboHrome to prevent, detect, and respond to money laundering, terrorist financing, fraud, sanctions evasion, payment abuse, refund abuse, chargeback abuse, and other illegal or suspicious activities.

Money laundering is the process by which criminals attempt to disguise the origin, ownership, movement, or destination of proceeds derived from illegal activity. Terrorist financing refers to the provision, collection, or movement of funds or assets with the intention or knowledge that they may be used to support terrorist acts, terrorist organizations, or individuals involved in terrorism.

ReboHrome does not tolerate any use of its website, services, payment systems, collectible products, randomized pack features, accounts, account restrictions, marketplace functionality, or business relationships for unlawful, fraudulent, abusive, or suspicious purposes. We reserve the right to refuse service, cancel orders, suspend transactions, restrict accounts, delay account actions, request additional verification, restrict access to products or services, contest chargebacks, and report suspicious activity to appropriate parties where required or permitted by applicable law.

This Policy applies to all users, customers, visitors, buyers, partners, suppliers, contractors, agents, and any other persons or entities who interact with ReboHrome, use our website, purchase products, open randomized packs, make payments, receive payments, request refunds, file disputes, or otherwise engage with our services.

2. Purpose of this Policy

The purpose of this AML Policy is to prevent ReboHrome from being used for money laundering, terrorist financing, fraud, sanctions evasion, payment abuse, chargeback abuse, refund abuse, or other unlawful activity. It also establishes a framework for identifying, assessing, monitoring, and mitigating financial crime risks; reviewing customers and transactions where necessary; defining when additional information or documents may be requested; explaining how suspicious activity may be detected, reviewed, escalated, restricted, or reported; and protecting ReboHrome, its customers, partners, payment processors, card networks, logistics providers, and the wider financial system from abuse.

This Policy should be read together with our Terms of Service, Privacy Policy, Refund & Shipping Policy, Compliance Notice, and any other policies published on rebohrome.com.

3. Scope of Application

This Policy applies to all activity connected with ReboHrome, including website access, account creation, browsing, ordering, purchasing, randomized pack purchases, randomized pack openings or reveals, digital collectible delivery, physical shipments, payment processing, deposits, balance activity, account restrictions, refunds, chargebacks, disputes, customer communication, supplier or partner relationships, affiliate or promotional activity where applicable, and any transaction or attempted transaction involving ReboHrome.

This Policy applies whether the activity is conducted directly through rebohrome.com, through a third-party payment processor, through a logistics provider, through customer support, through email, through Telegram, through blockchain payments, or through any other channel associated with ReboHrome.

4. Risk-Based Approach

ReboHrome applies a risk-based approach to AML, counter-terrorist financing, sanctions, fraud prevention, and payment security compliance. This means that the level of review, verification, monitoring, and control may vary depending on the level of risk associated with a customer, account, order, transaction, jurisdiction, payment method, delivery address, product type, pack activity, refund request, refund request, dispute history, or other relevant factor.

Risk factors may include the customer’s country of residence or billing address, the shipping destination, the payment method used, inconsistencies between billing, shipping, account, device, IP, Telegram, or payment information, order value, order frequency, randomized pack activity, repeated deposits and account restrictions, unusual purchasing patterns, attempted use of multiple identities, cards, accounts, wallets, or addresses, links to high-risk jurisdictions, sanctions exposure, fraud indicators, suspicious chargeback behavior, refusal to provide requested information, use of false or misleading information, unusual refund requests, transactions that appear to have no legitimate commercial purpose, and activity inconsistent with normal collector behavior.

Where risk is considered low, ReboHrome may proceed with standard processing. Where risk is medium or high, ReboHrome may conduct additional checks, request supporting documentation, delay processing, restrict account restrictions, cancel the transaction, refuse service, or take other measures described in this Policy.

5. Customer Due Diligence

ReboHrome may carry out customer due diligence where appropriate. Customer due diligence is the process of collecting and reviewing information to understand who the customer is, whether the transaction is legitimate, and whether there are any indications of unlawful activity, unauthorized payment use, payment abuse, refund abuse, chargeback abuse, or other suspicious conduct.

Depending on the nature of the order or activity, ReboHrome may request full legal name, email address, phone number, Telegram username, billing address, shipping address, proof of identity, proof of address, payment confirmation, cardholder confirmation, business registration documents where applicable, proof of authorization to act on behalf of a company, information about the purpose of the purchase, information about the source of funds where appropriate, wallet information, transaction hashes, and any other information reasonably required to verify the transaction or account activity.

ReboHrome may refuse to process an order, provide services, approve a account restriction, issue a refund, or continue an account relationship if the customer fails to provide requested information, provides false or misleading information, or if the information provided cannot be verified to ReboHrome’s reasonable satisfaction.

6. Enhanced Due Diligence

Enhanced Due Diligence, or EDD, may be applied where a customer, order, payment, jurisdiction, transaction, randomized pack activity, refund request, refund request, or dispute history presents a higher level of risk.

Enhanced Due Diligence may include requesting additional identification documents, requesting additional payment verification, requesting proof of ownership of a payment method, requesting proof of wallet ownership, requesting clarification of the purpose of the transaction, reviewing order history, reviewing randomized pack activity, reviewing account history, reviewing chargeback or refund history, checking sanctions or watchlist exposure, verifying whether the customer is acting on behalf of another person or entity, manually reviewing orders before shipment, placing account restrictions or account functions on hold until review is complete, refusing or cancelling the order, or restricting the account.

Enhanced Due Diligence may be applied in situations including high-value orders, repeated orders in a short period, multiple failed payment attempts, inconsistent billing and shipping information, use of multiple cards or payment accounts, delivery to freight forwarders or reshipping services, unusual refund requests, repeated chargebacks, refund requests following suspicious payment activity, suspected identity theft, suspected use of stolen payment information, suspected sanctions exposure, or customer behavior that appears evasive, aggressive, deceptive, inconsistent, or abusive.

7. Sanctions Compliance

ReboHrome does not knowingly conduct business with individuals, entities, organizations, countries, regions, or parties subject to applicable sanctions, embargoes, trade restrictions, or other legal prohibitions.

ReboHrome may screen customers, orders, payments, delivery addresses, suppliers, wallets, transaction identifiers, or business partners against sanctions lists or other restricted-party databases where appropriate. Screening may be conducted directly by ReboHrome or by third-party service providers, including payment processors, banks, logistics providers, fraud prevention tools, compliance vendors, or blockchain analytics providers.

If ReboHrome identifies a potential sanctions match or restricted-party risk, we may place the order or account on hold, request additional information, refuse the transaction, cancel the order, block access to services, withhold shipment, restrict account restrictions, notify relevant service providers, and report the matter to competent authorities where required or permitted by law.

Restricted Jurisdictions

ReboHrome does not provide services to users who are located in, resident in, incorporated in, or acting on behalf of jurisdictions, persons, entities, or regions subject to applicable sanctions, embargoes, or trade restrictions, including sanctions administered by the United Nations, the European Union, OFAC, or other competent authorities.

ReboHrome may also restrict or refuse access from jurisdictions where digital collectibles, randomized packs, loot boxes, gacha-style mechanics, online gaming, or similar digital products are prohibited, restricted, or require local authorization. This may include jurisdictions such as Belgium where applicable.

ReboHrome may use IP information, billing information, shipping information, payment metadata, account information, wallet details, device signals, third-party screening tools, and other relevant indicators to identify restricted jurisdiction risk.

8. Prohibited Activities

Users, customers, partners, and third parties are strictly prohibited from using ReboHrome, rebohrome.com, or any related service for money laundering, terrorist financing, fraud, sanctions evasion, identity theft, use of stolen payment cards or payment accounts, use of false or forged documents, concealment of beneficial ownership, transactions involving proceeds of crime, illegal resale schemes, unauthorized commercial activity, abuse of refund, return, or chargeback systems, testing stolen payment details, structuring transactions to avoid review, using third parties to conceal the true buyer, payer, recipient, wallet owner, or source of funds, manipulation of marketplace or randomized pack systems, exploitation of technical errors, or any activity prohibited by applicable law.

Any attempt to engage in prohibited activity may result in cancellation of orders, account restriction, account restriction restriction or denial, refusal of future service, reporting to payment processors, reporting to law enforcement, or other actions ReboHrome considers necessary and legally permitted.

9. Randomized Pack and Collector Activity Monitoring

Because ReboHrome may offer randomized packs, mystery packs, case-style products, drop-style products, and other collector features involving uncertain results, ReboHrome may monitor such activity for abuse, fraud, technical manipulation, payment misuse, and suspicious financial patterns.

Review may be triggered by patterns such as repeated high-value pack purchases followed by immediate refund requests, repeated disputes after unfavorable pack results, attempts to manipulate pack mechanics, exploitation of technical errors, use of multiple accounts to access promotions or bypass restrictions, aggressive or deceptive refund demands, or activity inconsistent with normal collector and entertainment use.

Randomized pack losses, disappointment, receipt of lower-value items, receipt of duplicate items, or disagreement with reference values do not themselves indicate a platform error and do not create a refund right unless required by applicable law or confirmed by ReboHrome under the Refund & Shipping Policy.

10. Transaction Monitoring

ReboHrome may monitor orders, payments, deposits, refunds, chargebacks, account activity, randomized pack activity, account restrictions, customer communications, shipping information, device information, IP data, Telegram information, wallet data, and other relevant indicators to identify unusual, suspicious, fraudulent, or unlawful activity.

Examples of activity that may trigger review include unusually large orders, multiple orders using different names but similar payment or delivery details, multiple failed payment attempts, use of several cards by the same customer, orders placed from a high-risk location, mismatch between IP location, billing address, shipping address, and account information, requests to change shipping details after payment, requests to ship to a third party without clear explanation, excessive refund or chargeback activity, pressure to process an order urgently, refusal to provide verification, use of disposable email addresses, suspicious communication patterns, attempts to bypass website rules, and attempts to manipulate payment, account restriction, or randomized pack controls.

Monitoring may be automated, manual, or a combination of both. ReboHrome is not required to disclose the specific rules, systems, thresholds, or indicators used for monitoring, as doing so may compromise security and compliance controls.

11. Order Holds, Cancellations, Account restriction Holds, and Refusal of Service

ReboHrome reserves the right to place any order, transaction, account function, shipment, refund, or account restriction on hold while conducting checks. During this period, shipment, access, refunds, account restrictions, or other account actions may be delayed and customer support may request additional information.

ReboHrome may cancel, refuse, restrict, delay, or deny an order, transaction, refund, account restriction, or account action if the customer does not pass verification, fails to respond to information requests, provides incomplete or misleading information, appears to use unauthorized payment details, appears suspicious or fraudulent, may violate sanctions or applicable law, creates unacceptable legal, financial, operational, payment, security, or reputational risk, or has previously engaged in abusive, fraudulent, or suspicious behavior.

Where an order is cancelled, refunds may be issued in accordance with the Refund & Shipping Policy, payment processor rules, and applicable law. However, ReboHrome may delay or refuse a refund where required or permitted by law, where fraud is suspected, where the product has already been delivered or revealed, where a payment provider requires review, or where a competent authority requires further review.

12. Refunds and Chargebacks

Refunds and chargebacks may create financial crime, fraud, and payment abuse risks. ReboHrome may review refund requests and disputes to ensure that they are legitimate and consistent with our policies.

ReboHrome may refuse, delay, or investigate refund requests where the request is inconsistent with order history, the customer repeatedly purchases and requests refunds, the customer requests a refund to a different payment method, refund requests appear to be used to move funds, the original payment appears suspicious, the order is linked to a chargeback or dispute, the product has already been shipped, delivered, opened, revealed, assigned, or credited, the request conflicts with the Refund & Shipping Policy, or the customer provides false or misleading information.

ReboHrome may contest chargebacks and provide evidence to payment processors, banks, card networks, fraud prevention vendors, and other relevant parties. Evidence may include account records, acceptance of terms, IP logs, device information, payment records, delivery records, randomized pack opening or reveal records, communication history, Telegram information, shipping records, and other relevant information.

Refunds, where approved, will generally be returned to the original payment method unless otherwise required by law or payment processor rules.

13. Third-Party Payment Providers

ReboHrome may use third-party payment processors, banks, card networks, fraud prevention tools, compliance vendors, identity verification providers, blockchain analytics providers, logistics providers, and other service providers to process transactions and support AML, fraud prevention, payment security, and sanctions compliance.

These providers may conduct their own checks, request information, decline payments, freeze payments, delay settlement, reverse transactions, flag activity, restrict accounts, or report suspicious activity in accordance with their own legal, regulatory, contractual, and risk obligations.

ReboHrome is not responsible for independent decisions made by third-party payment providers, banks, card networks, financial institutions, wallet providers, blockchain networks, or logistics providers. ReboHrome may rely on information received from such providers when assessing risk and deciding whether to accept, reject, suspend, restrict, or cancel a transaction or account action.

14. Suspicious Activity Reporting

Where ReboHrome identifies activity that may be suspicious, unlawful, fraudulent, abusive, or connected with money laundering, terrorist financing, sanctions evasion, payment abuse, refund abuse, chargeback abuse, or other financial crime, ReboHrome may escalate the matter internally and, where required or permitted by applicable law, report the activity to competent authorities, regulators, payment processors, banks, card networks, logistics providers, fraud prevention providers, or law enforcement agencies.

ReboHrome is not required to inform the customer that a report has been made or that suspicious activity is being reviewed. In some circumstances, notifying the customer may be prohibited by law or may compromise an investigation.

15. Record Keeping

ReboHrome may retain records related to customers, accounts, orders, deposits, transactions, randomized pack activity, reveal logs, verification requests, communications, refunds, chargebacks, fraud reviews, AML reviews, sanctions checks, account restrictions, wallet details, shipment records, and suspicious activity assessments.

Such records may be retained for as long as reasonably necessary to comply with legal, tax, accounting, regulatory, security, fraud prevention, dispute resolution, and business requirements. Where applicable law requires a specific retention period, ReboHrome will retain records for at least that period.

16. Data Protection and Confidentiality

ReboHrome processes personal data in accordance with its Privacy Policy and applicable data protection laws. AML, KYC, fraud prevention, sanctions compliance, payment dispute handling, and platform security may require ReboHrome to collect, use, store, review, and share certain personal data.

Such data may be shared with payment processors, banks, card networks, fraud prevention service providers, verification providers, blockchain analytics providers, logistics providers, professional advisers, law enforcement agencies, regulators, competent authorities, and other parties where required or permitted by law.

17. Customer Responsibilities

By using rebohrome.com or purchasing from ReboHrome, the customer agrees to provide accurate, complete, and up-to-date information; use only payment methods that the customer is legally authorized to use; not use ReboHrome for illegal, fraudulent, abusive, or suspicious activity; not attempt to conceal identity, location, source of funds, wallet ownership, or transaction purpose; respond to reasonable verification requests; comply with all applicable laws and regulations; not attempt to bypass AML, fraud prevention, sanctions, payment, randomized pack, account restriction, or security controls; notify ReboHrome if submitted information changes; and cooperate where additional review is required.

Failure to comply with these responsibilities may result in order cancellation, account restriction, account restriction restriction, refusal of service, reporting to relevant parties, or other appropriate action.

18. Politically Exposed Persons

A Politically Exposed Person, or PEP, is generally an individual who holds or has held a prominent public function, as well as certain family members or close associates of such a person. ReboHrome may apply additional review measures where a customer, beneficial owner, payer, recipient, wallet owner, or related party appears to be a PEP or connected to a PEP.

19. High-Risk Jurisdictions

ReboHrome may apply additional scrutiny to orders, customers, payments, shipments, wallets, account restrictions, or account activity connected to jurisdictions considered high risk for money laundering, terrorist financing, sanctions evasion, fraud, corruption, weak regulatory controls, excessive chargeback risk, or other financial crime risks.

ReboHrome may restrict or refuse transactions involving certain jurisdictions where required by law or where the risk is considered unacceptable.

20. Beneficial Ownership

Where a customer acts on behalf of a company, organization, trust, partnership, or other legal entity, ReboHrome may request information about the ultimate beneficial owner, including company name, registration number, registered address, directors or managers, ownership structure, ultimate beneficial owners, proof of authorization for the person placing the order, and business purpose of the transaction.

ReboHrome may refuse to deal with entities whose ownership, control structure, source of funds, or transaction purpose cannot be reasonably understood or verified.

21. Internal Controls

ReboHrome maintains internal controls designed to reduce AML, fraud, sanctions, payment abuse, chargeback abuse, refund abuse, and financial crime risks. These controls may include transaction monitoring, customer review procedures, sanctions screening, order risk scoring, payment verification, randomized pack activity review, security review, refund review, chargeback monitoring, staff awareness, escalation procedures, record keeping, and periodic review of this Policy.

The exact nature of these controls may change from time to time and may not be publicly disclosed for security and fraud prevention reasons.

22. Cooperation with Authorities and Service Providers

ReboHrome may cooperate with law enforcement agencies, regulators, courts, payment processors, banks, card networks, fraud prevention services, identity verification providers, logistics providers, blockchain analytics providers, and other competent parties where required or permitted by law.

Such cooperation may include providing information about customers, orders, payments, refunds, shipments, account activity, randomized pack activity, account restrictions, wallet details, communications, suspected fraud, suspected money laundering, suspected terrorist financing, suspected sanctions violations, chargeback abuse, refund abuse, or other unlawful activity.

ReboHrome may disclose information without prior notice to the customer where required or permitted by law, where necessary to protect ReboHrome’s rights, or where necessary to prevent fraud, financial crime, or harm to others.

23. No Guarantee of Service

Nothing in this Policy creates an obligation for ReboHrome to accept any customer, process any payment, ship any order, provide any pack, approve any refund, approve any account restriction, or continue any business relationship.

ReboHrome reserves the right to refuse or discontinue service at its discretion where legally permitted, especially where AML, fraud, sanctions, payment, operational, legal, security, or reputational risks are identified.

24. False or Misleading Information

Providing false, inaccurate, incomplete, forged, stolen, or misleading information is strictly prohibited. This includes false names, false addresses, fake documents, altered documents, stolen identity information, unauthorized payment information, misleading explanations of transaction purpose, attempts to hide the true recipient of goods, attempts to hide wallet ownership, or attempts to hide the true source of funds.

If ReboHrome discovers or reasonably suspects that false or misleading information has been provided, we may cancel orders, restrict access, refuse future transactions, delay or deny account restrictions, retain relevant records, notify service providers, and report the matter where required or permitted by law.

25. Relationship with Other Policies

This AML Policy forms part of ReboHrome’s broader compliance and risk management framework. It should be read together with the Terms of Service, Privacy Policy, Refund & Shipping Policy, Compliance Notice, and any other policy or notice published on rebohrome.com.

In the event of a conflict between this AML Policy and another policy, ReboHrome will interpret the documents in a manner that best supports legal compliance, fraud prevention, customer protection, payment security, and risk mitigation, subject to applicable law.

26. Policy Review and Updates

ReboHrome may review, update, amend, or replace this AML Policy from time to time to reflect changes in applicable law, business operations, payment provider requirements, sanctions or regulatory expectations, emerging fraud or financial crime risks, improvements to internal procedures, and operational or technical changes.

The updated version will be published on rebohrome.com. Unless otherwise stated, changes take effect from the date they are posted. Continued use of the website after publication of an updated Policy means that the user acknowledges the updated Policy.

27. Contact Information

Company: Private Enterprise “REBOHROME”

Website: https://www.rebohrome.com

Email: support@rebohrome.com

Address: 04050, Ukraine, Kyiv, Mykoly Murashka Street, Building 6, Apartment 90

28. Final Statement

ReboHrome is committed to operating responsibly and preventing misuse of its website, services, payment systems, collectible products, randomized pack features, account restrictions, and business relationships. We take money laundering, terrorist financing, fraud, sanctions evasion, payment abuse, refund abuse, chargeback abuse, and other financial crime risks seriously.

By using rebohrome.com, placing an order, making a payment, opening or revealing a randomized pack, requesting a account restriction, requesting a refund, filing a dispute, or interacting with ReboHrome, you acknowledge that you have read, understood, and agreed to this AML Policy.

Platform balance is intended for purchases on ReboHrome and is not withdrawable unless ReboHrome expressly enables such functionality in the future.