MRNMarket KYC & AML Policy

Effective Date: 27 February 2026

Last Updated: 27 February 2026

Issued by: MRN Global Market LLC, doing business as MRNMarket

Address: 1001 S Main St, STE 500, Kalispell, MT 59901-1498, United States

Website: https://www.mrnmarket.com

Legal Contact: legal@mrnmarket.com

Support Contact: support@mrnmarket.com

1. Purpose of This Policy

This KYC & AML Policy explains how MRNMarket may conduct identity verification, business verification, fraud prevention, sanctions screening, anti-money laundering review, risk assessment, and compliance review for Users and Transactions.

This Policy applies to Users, including Buyers, Sellers, Affiliates, Delivery Partners, Service Providers, business partners, and other persons or entities that access or use the Platform.

This Policy should be read together with the MRNMarket Terms & Conditions, Definitions Policy, Privacy Policy, Acceptable Use Policy, Payment & Payout Policy, Payment Review and Release Policy, Seller Verification Policy, Affiliate Verification Policy, and other applicable MRNMarket policies.

MRNMarket is not a bank, money transmitter, licensed escrow provider, payment processor, financial institution, or financial adviser unless expressly stated in writing. This Policy is designed to support platform integrity, user safety, payment review, fraud prevention, sanctions compliance, and legal compliance.

2. Important Regulatory Position

MRNMarket operates primarily as a marketplace technology platform. MRNMarket may conduct KYC, KYB, AML, sanctions, fraud, and compliance review as part of its platform risk controls.

This Policy does not mean that MRNMarket is acting as a regulated bank, money transmitter, payment processor, escrow provider, or financial institution.

Payment-related activities may be processed by third-party Payment Processors, banks, card networks, digital wallets, financial institutions, or other payment service providers. Those third parties may apply their own KYC, AML, sanctions, fraud, risk, payment hold, reserve, and compliance rules.

3. Risk-Based Compliance Approach

MRNMarket may apply a risk-based approach to verification, AML review, fraud prevention, sanctions screening, and Transaction monitoring.

A risk-based approach means that MRNMarket may apply different levels of review depending on factors such as:

1. User type;
2. location;
3. business type;
4. product or service category;
5. Transaction value;
6. Transaction frequency;
7. payment method;
8. payout method;
9. delivery method;
10. account history;
11. dispute history;
12. refund or chargeback activity;
13. sanctions risk;
14. fraud indicators;
15. regulatory requirements;
16. Payment Processor requirements; and
17. platform risk.

OFAC encourages organizations subject to U.S. jurisdiction, and foreign entities that conduct business in or with the United States, U.S. persons, or U.S.-origin goods or services, to use a risk-based sanctions compliance program that includes management commitment, risk assessment, internal controls, testing/auditing, and training. (ofac.treasury.gov)

4. KYC — Know Your Customer

“KYC” means Know Your Customer or similar identity verification procedures used to verify a person’s identity, account details, eligibility, location, risk profile, or transaction activity.

MRNMarket may request or review information such as:

1. full legal name;
2. date of birth;
3. residential address;
4. email address;
5. phone number;
6. government identification;
7. tax identification information;
8. payment account information;
9. selfie, photo, or liveness check where permitted;
10. proof of address;
11. account activity;
12. transaction history;
13. source of funds or source of wealth where appropriate;
14. sanctions screening results;
15. fraud screening results; and
16. other information required by MRNMarket, Payment Processors, or applicable law.

MRNMarket may require KYC before allowing certain activities, including account access, purchasing, selling, payouts, affiliate commissions, delivery partner participation, service provider participation, high-value Transactions, refunds, or dispute resolution.

5. KYB — Know Your Business

“KYB” means Know Your Business or similar business verification procedures used to verify a business, legal entity, representative, beneficial owner, tax status, registration, ownership, or authority.

MRNMarket may request or review business information such as:

1. legal business name;
2. trade name or DBA;
3. business address;
4. business registration documents;
5. tax identification number;
6. business license or permit;
7. ownership structure;
8. beneficial ownership information;
9. directors, officers, managers, or authorized representatives;
10. proof of authority to act for the business;
11. website, store, or business profile;
12. product or service categories;
13. payment account details;
14. bank or payout information;
15. sanctions screening information;
16. fraud screening information;
17. compliance documents; and
18. other information required by MRNMarket, Payment Processors, or applicable law.

Business Users are responsible for ensuring that all KYB information is accurate, current, complete, and not misleading.

6. Beneficial Ownership Review

Where appropriate, MRNMarket may request information about beneficial owners, controlling persons, directors, managers, officers, representatives, or other persons with ownership or control over a business User.

Beneficial ownership review may be used to:

1. verify business identity;
2. confirm authority;
3. detect shell entities;
4. prevent fraud;
5. support sanctions screening;
6. support AML review;
7. comply with Payment Processor requirements;
8. comply with applicable law;
9. evaluate risk; and
10. protect the Platform.

MRNMarket may request ownership percentages, control information, identification documents, addresses, dates of birth, tax information, or other verification information.

7. AML — Anti-Money Laundering Review

“AML” means anti-money laundering laws, regulations, rules, procedures, screening, and monitoring related to detecting or preventing money laundering, terrorist financing, sanctions evasion, fraud, corruption, tax evasion, and related financial crimes.

MRNMarket may review Users, Accounts, Listings, Orders, Transactions, payment activity, payout activity, refunds, returns, chargebacks, affiliate commissions, delivery activity, communications, and other Platform activity for AML and financial crime risk.

AML review may include:

1. identity verification;
2. business verification;
3. beneficial ownership review;
4. sanctions screening;
5. risk scoring;
6. transaction monitoring;
7. unusual activity review;
8. payment method review;
9. payout method review;
10. source of funds review where appropriate;
11. source of wealth review where appropriate;
12. dispute and chargeback review;
13. refund pattern review;
14. account relationship review;
15. geographic risk review;
16. product category risk review;
17. communication review where permitted; and
18. escalation to compliance or legal review.

8. Sanctions Screening

MRNMarket may screen Users, beneficial owners, representatives, counterparties, delivery destinations, payment details, Transactions, Listings, and related activity against sanctions, restricted-party, watchlist, export control, anti-terrorism, and similar lists where appropriate.

Sanctions review may include screening against lists or programs administered by governmental or regulatory authorities, including U.S. sanctions programs administered by OFAC.

OFAC administers and enforces U.S. economic and trade sanctions programs against targeted foreign governments, individuals, groups, and entities based on U.S. national security and foreign policy goals. (ofac.treasury.gov)

MRNMarket may block, reject, restrict, suspend, cancel, review, or report activity if sanctions concerns arise.

Users must not use the Platform to evade sanctions, export controls, embargoes, restricted-party rules, anti-terrorism laws, or similar legal requirements.

9. Prohibited High-Risk Activity

Users must not use the Platform for:

1. money laundering;
2. terrorist financing;
3. sanctions evasion;
4. fraud;
5. bribery or corruption;
6. tax evasion;
7. trafficking;
8. stolen goods;
9. counterfeit goods;
10. illegal gambling;
11. illegal financial services;
12. unauthorized money transmission;
13. unauthorized escrow activity;
14. illegal weapons activity;
15. illegal drugs or controlled substances;
16. prohibited adult exploitation activity;
17. cybercrime;
18. identity theft;
19. stolen payment methods;
20. chargeback abuse;
21. fake transactions;
22. false delivery confirmations;
23. shell company abuse;
24. hidden beneficial ownership;
25. fake referrals or commission fraud;
26. off-platform payment circumvention;
27. or any other illegal, deceptive, harmful, or prohibited activity.

MRNMarket may restrict or terminate activity that presents unacceptable legal, financial, operational, reputational, fraud, sanctions, or compliance risk.

10. Information Users Must Provide

Users must provide accurate, complete, current, and truthful information when requested by MRNMarket, Payment Processors, verification providers, or other authorized service providers.

Users may be required to provide:

1. identity documents;
2. business documents;
3. tax documents;
4. proof of address;
5. proof of ownership;
6. proof of authority;
7. payment or payout information;
8. bank account details;
9. product compliance documents;
10. shipping or delivery documents;
11. invoices;
12. transaction evidence;
13. source of funds information;
14. source of wealth information;
15. affiliate promotional information;
16. beneficial ownership information;
17. licenses, permits, or registrations;
18. or other information needed for risk review or legal compliance.

Failure to provide requested information may result in account restrictions, transaction delays, payment review, payout holds, refund delays, listing removal, suspension, termination, or other Enforcement Actions.

11. Ongoing Monitoring

MRNMarket may conduct ongoing monitoring of Users, Accounts, Listings, Orders, Transactions, payouts, refunds, chargebacks, communications, delivery information, and other Platform activity.

Ongoing monitoring may be used to:

1. detect fraud;
2. detect suspicious activity;
3. review unusual transaction patterns;
4. identify sanctions risk;
5. identify prohibited activity;
6. evaluate seller performance;
7. review buyer conduct;
8. assess affiliate activity;
9. protect payment systems;
10. support dispute review;
11. comply with Payment Processor requirements;
12. comply with applicable law; and
13. protect MRNMarket and Users.

MRNMarket may update User risk ratings and require additional information based on ongoing monitoring.

12. Enhanced Due Diligence

MRNMarket may conduct enhanced due diligence for higher-risk Users, Transactions, Listings, categories, locations, payment methods, payout methods, or account activity.

Enhanced due diligence may include:

1. additional identity verification;
2. additional business verification;
3. beneficial ownership review;
4. source of funds review;
5. source of wealth review;
6. product or service compliance review;
7. license or permit review;
8. sanctions escalation;
9. manual review;
10. transaction limits;
11. payout limits;
12. reserve requirements;
13. additional documentation;
14. review of related Accounts;
15. review of communications where permitted;
16. or other risk controls.

Enhanced due diligence does not guarantee approval, payout, transaction completion, or continued access.

13. Payment Review, Holds, and Release

Where permitted by applicable law and Payment Processor rules, payments, refunds, payouts, settlements, reserves, or related amounts may be subject to review, hold, delay, restriction, reserve, offset, reversal, or release procedures.

Reasons may include:

1. incomplete verification;
2. fraud risk;
3. AML risk;
4. sanctions risk;
5. chargeback risk;
6. dispute review;
7. delivery confirmation;
8. seller performance;
9. buyer conduct;
10. suspicious activity;
11. account linkage;
12. legal requirements;
13. Payment Processor requirements;
14. tax requirements;
15. or platform risk management.

Payment Review and Release or Payment Holds do not mean MRNMarket acts as a bank, money transmitter, licensed escrow provider, payment processor, financial institution, custodian of funds, or financial adviser.

14. Refusal, Restriction, Suspension, or Termination

MRNMarket may refuse, restrict, suspend, terminate, or limit access to the Platform if:

1. verification is incomplete;
2. information is inaccurate, expired, false, or misleading;
3. documents cannot be verified;
4. beneficial ownership cannot be confirmed;
5. sanctions concerns arise;
6. AML concerns arise;
7. fraud concerns arise;
8. risk is unacceptable;
9. Payment Processor rules require action;
10. required documents are not provided;
11. suspicious activity is detected;
12. User conduct violates MRNMarket policies;
13. law enforcement, regulator, bank, card network, or Payment Processor requests action;
14. or applicable law requires or permits action.

MRNMarket may also cancel Orders, remove Listings, delay payouts, reverse commissions, restrict refunds, preserve records, or report activity where permitted or required by law.

15. Reporting and Cooperation

MRNMarket may report suspicious, unlawful, prohibited, or high-risk activity to Payment Processors, banks, card networks, regulators, law enforcement, government authorities, rights owners, affected Users, or other appropriate parties where permitted or required by law.

Users agree to cooperate with MRNMarket, Payment Processors, banks, regulators, law enforcement, and other authorized parties in connection with compliance review, investigations, disputes, chargebacks, sanctions screening, AML review, fraud prevention, or legal obligations.

MRNMarket may preserve records where necessary for legal, compliance, fraud prevention, dispute, tax, accounting, regulatory, or enforcement purposes.

16. User Responsibilities

Users are responsible for:

1. providing accurate and current information;
2. updating information when it changes;
3. using the Platform lawfully;
4. avoiding prohibited activity;
5. complying with sanctions, AML, tax, customs, product compliance, export/import, privacy, and consumer protection laws;
6. responding to verification requests;
7. providing requested documents;
8. ensuring business representatives are authorized;
9. disclosing beneficial ownership where requested;
10. using payment and payout methods lawfully;
11. avoiding chargeback abuse, refund abuse, and payout fraud;
12. maintaining accurate records; and
13. complying with MRNMarket policies.

Users must not attempt to bypass verification, conceal identity, hide beneficial ownership, use fake documents, use stolen payment information, evade sanctions, or structure activity to avoid review.

17. Privacy and Data Protection

MRNMarket may collect, use, store, share, and process Personal Data for KYC, KYB, AML, sanctions, fraud prevention, payment review, risk review, legal compliance, dispute support, and enforcement purposes.

Personal Data may be shared with verification providers, Payment Processors, banks, card networks, digital wallets, fraud prevention providers, compliance providers, delivery partners, service providers, regulators, law enforcement, or other parties where permitted or required by law.

For more information, review the MRNMarket Privacy Policy and Cookie & Tracking Policy.

18. No Guarantee

MRNMarket may use manual and automated tools to support verification, fraud prevention, sanctions screening, AML review, transaction monitoring, and risk assessment.

However, MRNMarket does not guarantee that all fraud, suspicious activity, sanctions risk, AML risk, prohibited activity, illegal activity, or policy violations will be detected, prevented, blocked, reported, or resolved.

Verification, screening, or monitoring does not guarantee User performance, product quality, delivery success, transaction outcome, legal compliance, payment success, payout success, or absence of fraud.

19. Changes to This Policy

MRNMarket may update this KYC & AML Policy from time to time to reflect changes in the Platform, applicable law, business operations, Payment Processor requirements, marketplace practices, sanctions programs, fraud risks, risk controls, operational needs, or other policies.

Updated versions will be published on the Platform with a revised effective date or last updated date.

Continued use of the Platform after updates are published means the User acknowledges the updated Policy.

Where required by law, MRNMarket may provide additional notice or request consent for material changes.

20. Policy Hierarchy

This Policy should be read together with the MRNMarket Terms & Conditions, Definitions Policy, Privacy Policy, Acceptable Use Policy, Payment & Payout Policy, Payment Review and Release Policy, Seller Verification Policy, Affiliate Verification Policy, and other applicable policies.

If this Policy conflicts with the Terms & Conditions or another controlling MRNMarket policy, the controlling policy will apply, subject to rights that cannot be waived under applicable law.

21. Contact Information

For questions about this KYC & AML Policy, contact:

MRN Global Market LLC

1001 S Main St, STE 500

Kalispell, MT 59901-1498

United States

Website: https://www.mrnmarket.com

Legal Contact: legal@mrnmarket.com

Support Contact: support@mrnmarket.com