Anti-Money Laundering and Counter-Terrorist Financing Policy

AML / CTF / KYC Policy

**Effective Date:01.05.2026

Company Name: Rebohrome

Website: https://rebohrome.com

Contact Email: store@rebohrome.com

Registered / Business Address: Not publicly disclosed

1. Introduction

Rebohrome is committed to maintaining high standards of legal, ethical, 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, and other illegal or suspicious activities.

Money laundering is the process by which criminals attempt to disguise the origin, ownership, 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, products, accounts, or business relationships for unlawful purposes. We reserve the right to refuse service, cancel orders, suspend transactions, request additional verification, restrict access to our website or services, and report suspicious activity to the appropriate authorities 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, make payments, receive payments, or otherwise engage with our services.

2. Purpose of this Policy

The purpose of this AML Policy is to:

1. Prevent Rebohrome from being used for money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful activities.
2. Establish a clear framework for identifying, assessing, monitoring, and mitigating financial crime risks.
3. Ensure that customers and transactions may be reviewed where necessary.
4. Define the circumstances under which Rebohrome may request additional information or documents.
5. Explain how suspicious activity may be detected, reviewed, escalated, restricted, or reported.
6. Protect Rebohrome, its customers, partners, payment processors, and the wider financial system from abuse.
7. Support compliance with applicable laws, regulations, payment provider requirements, card network rules, sanctions programs, and international AML standards.

This Policy should be read together with our Terms and Conditions, Privacy Policy, Refund Policy, Shipping Policy, and any other policies published on rebohrome.com.

3. Scope of Application

This Policy applies to all activity connected with Rebohrome, including but not limited to:

• website access and account creation;
• browsing, ordering, purchasing, or returning products;
• payment processing;
• refunds, chargebacks, and disputes;
• customer communication;
• supplier, vendor, or partner relationships;
• affiliate, promotional, or reseller activity, where applicable;
• 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, or through any other channel associated with Rebohrome.

4. Risk-Based Approach

Rebohrome applies a risk-based approach to AML and counter-terrorist financing compliance. This means that the level of review, verification, monitoring, and control may vary depending on the level of risk associated with a customer, order, transaction, jurisdiction, payment method, delivery address, product type, or other relevant factor.

Risk factors may include, but are not limited to:

• the customer’s country of residence or billing address;
• the shipping destination;
• the payment method used;
• inconsistencies between billing, shipping, and payment information;
• order value, order frequency, or unusual purchasing patterns;
• attempted use of multiple identities, cards, accounts, or addresses;
• links to high-risk jurisdictions;
• sanctions exposure;
• fraud indicators;
• suspicious chargeback behavior;
• refusal to provide requested information;
• use of false, incomplete, or misleading information;
• unusual refund requests;
• transactions that appear to have no legitimate commercial purpose.

Where the risk is considered low, Rebohrome may proceed with standard order processing. Where the risk is medium or high, Rebohrome may conduct additional checks, request supporting documentation, delay processing, cancel the transaction, 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.

Depending on the nature of the order or activity, Rebohrome may request one or more of the following:

• full legal name;
• email address;
• phone number;
• billing address;
• shipping address;
• proof of identity;
• proof of address;
• payment confirmation;
• cardholder confirmation;
• business registration documents, where the customer is a company;
• 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;
• any other information reasonably required to verify the transaction.

Rebohrome may refuse to process an order or provide services 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, or transaction 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 clarification of the purpose of the transaction;
• reviewing order 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 the order before shipment;
• placing the order on hold until review is complete;
• refusing or cancelling the order.

Enhanced Due Diligence may be applied in situations including but not limited to:

• 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;
• suspected identity theft;
• suspected use of stolen payment information;
• suspected sanctions exposure;
• customer behavior that appears evasive, aggressive, deceptive, or inconsistent.

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, or business partners against sanctions lists or other restricted-party databases where appropriate. Sanctions screening may be conducted directly by Rebohrome or by third-party service providers, including payment processors, banks, logistics providers, fraud prevention tools, or compliance vendors.

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;
• notify relevant service providers;
• report the matter to competent authorities where required or permitted by law.

Rebohrome reserves the right not to provide goods or services where doing so may expose Rebohrome to sanctions, legal, financial, regulatory, or reputational 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, forged, or misleading documents;
• concealment of beneficial ownership;
• transactions involving proceeds of crime;
• illegal resale schemes;
• unauthorized commercial activity;
• abuse of refund, return, or chargeback systems;
• use of the website to test stolen payment details;
• structuring transactions to avoid review;
• using third parties to conceal the true buyer, payer, recipient, or source of funds;
• any activity prohibited by applicable law.

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

9. Transaction Monitoring

Rebohrome may monitor orders, payments, refunds, chargebacks, account activity, customer communications, shipping information, device information, IP 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 placed 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, and shipping address;
• 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 or payment 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.

10. Order Holds, Cancellations, and Refusal of Service

Rebohrome reserves the right to place any order or transaction on hold while conducting checks. During this period, shipment may be delayed and customer support may request additional information.

Rebohrome may cancel or refuse an order if:

• the customer does not pass verification;
• the customer fails to respond to information requests;
• the information provided is incomplete, false, or misleading;
• the payment appears unauthorized;
• the order appears suspicious or fraudulent;
• the order may violate sanctions or applicable law;
• the transaction creates unacceptable legal, financial, operational, or reputational risk;
• the customer has previously engaged in abusive, fraudulent, or suspicious behavior.

Where an order is cancelled, refunds may be issued in accordance with our Refund 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, or where a payment provider, bank, or competent authority requires further review.

11. Refunds and Chargebacks

Refunds and chargebacks may create financial crime and fraud risks. Rebohrome may review refund requests to ensure that they are legitimate and consistent with our policies.

Rebohrome may refuse, delay, or investigate refund requests where:

• the refund request is inconsistent with the order history;
• the customer repeatedly purchases and requests refunds;
• the customer requests a refund to a different payment method;
• the customer uses refund requests to move funds;
• the original payment appears suspicious;
• the order is linked to a chargeback or dispute;
• the product has already been shipped or delivered;
• the refund request conflicts with our Refund Policy;
• the customer provides false or misleading information.

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

12. Third-Party Payment Providers

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

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

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

13. Suspicious Activity Reporting

Where Rebohrome identifies activity that may be suspicious, unlawful, fraudulent, or connected with money laundering, terrorist financing, sanctions evasion, 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, 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.

Suspicious activity may include, but is not limited to:

• transactions with no apparent legitimate purpose;
• use of false identities;
• use of stolen payment details;
• attempts to disguise the true buyer or recipient;
• transactions linked to sanctioned persons or jurisdictions;
• unusual refund behavior;
• repeated chargebacks;
• fraudulent claims;
• attempts to bypass verification;
• other activity that Rebohrome reasonably considers suspicious.

14. Record Keeping

Rebohrome may retain records related to customers, orders, transactions, verification requests, communications, refunds, chargebacks, fraud reviews, AML reviews, sanctions checks, and suspicious activity assessments.

Records may include:

• customer contact details;
• order details;
• payment-related information;
• shipping information;
• correspondence with the customer;
• verification documents;
• internal review notes;
• fraud or risk indicators;
• refund and chargeback records;
• records of decisions made under this Policy.

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.

15. Data Protection and Confidentiality

Rebohrome processes personal data in accordance with its Privacy Policy and applicable data protection laws.

AML, KYC, fraud prevention, and sanctions compliance 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;
• logistics providers;
• professional advisers;
• law enforcement agencies;
• regulators;
• competent authorities;
• other parties where required or permitted by law.

Rebohrome takes reasonable steps to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. However, users acknowledge that certain data processing may be necessary for compliance, security, fraud prevention, and transaction processing purposes.

16. Customer Responsibilities

By using rebohrome.com or purchasing from Rebohrome, the customer agrees to:

1. Provide accurate, complete, and up-to-date information.
2. Use only payment methods that the customer is legally authorized to use.
3. Not use Rebohrome for illegal, fraudulent, or suspicious activity.
4. Not attempt to conceal identity, location, source of funds, or transaction purpose.
5. Respond to reasonable verification requests.
6. Comply with all applicable laws and regulations.
7. Not attempt to bypass AML, fraud prevention, sanctions, payment, or security controls.
8. Notify Rebohrome if any submitted information changes.
9. Cooperate with Rebohrome where additional review is required.

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

17. 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, or related party appears to be a PEP or connected to a PEP. This does not automatically mean that the person is prohibited from using Rebohrome. However, additional checks may be required to understand the purpose of the transaction, source of funds, and potential risk.

18. High-Risk Jurisdictions

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

Rebohrome may determine high-risk jurisdictions based on:

• applicable law;
• sanctions programs;
• payment provider requirements;
• card network rules;
• government advisories;
• international AML standards;
• internal risk assessments;
• fraud and chargeback trends;
• logistics and delivery risks.

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

19. 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.

A beneficial owner is generally a natural person who ultimately owns, controls, or benefits from a legal entity or arrangement.

Rebohrome may request information such as:

• company name;
• registration number;
• registered address;
• directors or managers;
• ownership structure;
• ultimate beneficial owners;
• proof of authorization for the person placing the order;
• business purpose of the transaction.

Rebohrome may refuse to deal with entities whose ownership or control structure cannot be reasonably understood or verified.

20. Internal Controls

Rebohrome maintains internal controls designed to reduce AML, fraud, sanctions, and financial crime risks. These controls may include:

• transaction monitoring;
• customer review procedures;
• sanctions screening;
• order risk scoring;
• payment verification;
• refund review;
• chargeback monitoring;
• staff awareness;
• escalation procedures;
• record keeping;
• 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.

21. Staff Awareness and Escalation

Rebohrome may ensure that relevant personnel, contractors, or service providers involved in order processing, customer support, payments, refunds, or risk review are aware of AML, fraud prevention, and sanctions risks relevant to their role.

Where suspicious activity is identified, personnel may escalate the matter to the appropriate internal contact or decision-maker. The matter may then be reviewed and appropriate action may be taken, including requesting further information, cancelling an order, restricting service, or reporting the matter where required or permitted by law.

22. Cooperation with Authorities and Service Providers

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

Such cooperation may include providing information about:

• customers;
• orders;
• payments;
• refunds;
• shipping;
• account activity;
• communications;
• suspected fraud;
• suspected money laundering;
• suspected terrorist financing;
• suspected sanctions violations;
• 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, approve any refund, or continue any business relationship.

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

24. False or Misleading Information

Providing false, inaccurate, incomplete, forged, stolen, or misleading information is strictly prohibited.

This includes but is not limited to:

• 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 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, 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:

• Terms and Conditions;
• Privacy Policy;
• Refund Policy;
• Shipping Policy;
• Cookie Policy, where applicable;
• 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, and risk mitigation.

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;
• changes in business operations;
• changes in payment provider requirements;
• changes in sanctions or regulatory expectations;
• emerging fraud or financial crime risks;
• improvements to internal procedures;
• 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

If you have any questions about this AML Policy or need to provide information requested for verification, please contact Rebohrome at:

Company: Rebohrome

Website: https://rebohrome.com

Email: store@rebohrome.com

Address: Not publicly disclosed

28. Final Statement

Rebohrome is committed to operating responsibly and preventing misuse of its website, services, payment systems, and business relationships. We take money laundering, terrorist financing, fraud, sanctions evasion, and other financial crime risks seriously.

By using rebohrome.com, placing an order, making a payment, requesting a refund, or interacting with Rebohrome, you acknowledge that you have read, understood, and agreed to this AML Policy.