Know Your Business Customer Policy for Marketplaces

Status Notice — Program Launch Pending. This policy governs Know Your Business Customer obligations for the Tanqory marketplace functionality and takes full effect upon the launch of the marketplace. Until launch, the policy serves as the framework for vendor onboarding under existing Acceptable Use Policy requirements.

1) Purpose

This Policy implements the Know Your Business Customer ("KYBC") obligations that apply to Tanqory's planned marketplace functionality. Its principal regulatory anchor is Article 30 of EU Regulation 2022/2065 (the Digital Services Act, "DSA"), which requires online platforms allowing consumers to conclude distance contracts with traders to obtain, verify, and retain specified information about each trader before allowing the trader to use the platform's services. This Policy is also designed to support compliance with anti-money-laundering ("AML") obligations under the EU AMLD framework, with sanctions obligations administered by the United States Office of Foreign Assets Control ("OFAC"), and with Singapore's CDSA where applicable.

2) Scope

This Policy applies to the Tanqory marketplace functionality — that is, any service through which a third-party trader (a natural or legal person, including a self-employed individual) is permitted to offer products or services to end consumers via a Tanqory-operated platform surface and to conclude distance contracts with those consumers. This Policy does not apply to:

• A merchant operating a standalone Tanqory-powered storefront that contracts directly with its own customers without Tanqory acting as an intermediary marketplace. Such relationships are governed by the Merchant Agreement and the Acceptable Use Policy.
• Tanqory's first-party sales of Tanqory products and services to its customers.

Status: The Tanqory marketplace functionality has not yet been publicly launched as of the effective date of this Policy. This Policy applies as the binding framework upon launch. During the pre-launch period, Tanqory applies the Acceptable Use Policy and the Merchant Agreement to all vendor onboarding, and treats the KYBC requirements set out below as the controlling design specification for marketplace onboarding.

3) KYBC information requirements

In accordance with DSA Article 30(1), before allowing a trader to use Tanqory marketplace services for the promotion of messages on, or the offering of products or services to, consumers located in the European Union, Tanqory obtains the following information from the trader:

1. The trader's name, address, telephone number, and email address.
2. A copy of the identification document of the trader, or any other electronic identification as defined by Article 3 of EU Regulation (EU) No 910/2014 (eIDAS).
3. The payment account details of the trader.
4. Where the trader is entered in a trade register or similar public register, the trade register in which the trader is entered and its registration number or equivalent means of identification in that register.
5. A self-certification by the trader committing to offer only products or services that comply with the applicable rules of Union law.

Tanqory may collect additional information beyond the DSA Article 30(1) minimum where necessary for tax compliance (including DAC7 reporting where applicable to EU-resident sellers), for OFAC sanctions screening, or for the prevention of fraud and money laundering.

4) Verification mechanisms

Tanqory makes best efforts, in accordance with DSA Article 30(2), to assess whether the information referred to in Section 3 above is reliable and complete. Verification measures include:

• Cross-checking trader-supplied registration numbers against publicly accessible business registers in the trader's jurisdiction (for example, the EU Business Registers Interconnection System (BRIS), the Singapore ACRA register, the United Kingdom Companies House register, the Estonian Äriregister, and the Delaware Division of Corporations).
• Verification of the trader's email address and telephone number through confirmation challenges.
• Verification of the trader's payment account through a name-matching check against the registered legal name on the marketplace account.
• Use of identity-verification services for the natural person submitting the registration on the trader's behalf, where the natural person is an authorized representative of a legal person trader.
• Screening of the trader's name and beneficial owners against (i) EU consolidated sanctions list, (ii) United Nations Security Council Consolidated List, (iii) OFAC SDN List, (iv) United Kingdom OFSI Consolidated List, and (v) Singapore MAS sanctions lists.

The KYBC program launch is pending. The Company will perform Know Your Business Customer verification using a qualified verification provider, with the specific verification vendors, the verification workflow, and the operational owner of the KYBC queue documented in the marketplace operational runbook upon launch.

5) Reasonable-efforts standard

The verification obligation under DSA Article 30(2) is a best-efforts standard, not a guarantee. Tanqory's verification measures are designed to detect manifest non-compliance and obvious falsification. They do not constitute (a) certification of the trader's underlying business legitimacy, (b) endorsement of the trader's products or services, or (c) a guarantee against fraudulent registration. Where Tanqory has reasonable indications that an item of trader information is inaccurate, incomplete, or not up to date, Tanqory will request the trader to correct it without delay and, failing correction, will suspend the trader's use of the marketplace until the matter is resolved.

6) Suspension and termination triggers

Tanqory may suspend or terminate a trader's access to the marketplace, in addition to other remedies available under the Acceptable Use Policy, on any of the following grounds:

• Failure to provide the information required by Section 3 within the time period specified at request.
• Material inaccuracy or falsification of submitted information that is not corrected within a reasonable period after notice.
• Sanctions match against any of the lists named in Section 4 that is not resolved by documentation of an applicable exemption or licensing.
• Pattern of consumer complaints indicating systemic non-compliance with Union or national consumer-protection law, product-safety law, or intellectual-property law.
• Final judicial or administrative determination that the trader's offerings violate applicable law.
• Order from a competent authority requiring action against the trader.

Suspension and termination decisions are subject to the internal complaints handling and out-of-court dispute settlement mechanisms required by DSA Articles 20 and 21 where the trader is located in the European Union.

7) Periodic re-verification

Tanqory conducts periodic re-verification of trader information as follows:

• Triggered re-verification upon any material change in trader-supplied information, including change of legal name, registered address, beneficial owners, or payment account.
• Risk-based periodic review of high-risk traders, including traders in high-risk product categories (such as financial services, regulated goods, alcohol where supported, age-restricted goods) and traders established in higher-risk jurisdictions as designated by the European Commission under AMLD or by the Financial Action Task Force.
• Periodic re-verification of standard-risk traders on a risk-based basis.

8) Coordination with AML, sanctions, and anti-corruption policies

This Policy is read together with, and does not replace, Tanqory's broader compliance program. The relevant cross-policy responsibilities are:

• AML / Counter-Terrorist Financing. Beneficial-ownership information collected under Section 3 of this Policy and screening results from Section 4 are processed under Tanqory's AML/Sanctions Policy (aml-sanctions-policy.md). Records are retained as required by AMLD: for the duration of the business relationship and at least 5 years after its termination, subject to longer national retention periods up to 10 years where Member State law so requires.
• Anti-Corruption. Trader on-boarding screening includes adverse-media checks for indicators relevant to the Anti-Corruption Policy (anti-corruption-policy.md).
• Sanctions. OFAC, EU, UN, UK, and Singapore sanctions screening as described in Section 4 is performed on the trader, its beneficial owners, and any director or authorized representative on file. Hits are escalated to legal review prior to onboarding or transactional release.

9) Recordkeeping

Tanqory retains the information collected under Section 3 and the documentation of verification activities under Section 4 for the duration of the trader's relationship with the marketplace and for at least five (5) years following termination of the relationship, in accordance with AMLD Article 40(1). Personal data within these records is processed under the Privacy Policy and the Records of Processing Activities, and is retained beyond the standard retention period only where required by AML, tax, sanctions, or litigation-hold obligations.

10) Transparency-database publication

In accordance with DSA Article 30(7), Tanqory makes accessible to consumers, on the marketplace surface where the trader's product or service is offered, the following items of trader information:

• The trader's name, postal address, telephone number, and email address.
• The trade register and registration number, where applicable.
• The trader's self-certification statement under DSA Article 30(1)(e).

Tanqory does not publish copies of identification documents or payment-account details. Personal data of natural-person traders is published only to the extent required by DSA Article 30(7) and consistently with the GDPR principles of data minimization and purpose limitation.

11) Notice to authorities and consumers

Where Tanqory becomes aware, through the means in this Policy or through a notice under Article 16 of the DSA, of any information indicating that a product or service offered by a trader through the marketplace is illegal, Tanqory will (a) inform the consumers who acquired the product or service through the marketplace during the preceding six months, where contact details are available, of the illegality and the trader's identity, and any applicable remedies, in accordance with DSA Article 32, and (b) suspend the trader where appropriate under Section 6.

12) Cross-references

• Acceptable Use Policy: platform/acceptable-use-policy.md
• Terms of Service: platform/terms-of-service.md
• Merchant Agreement: platform/merchant-agreement.md
• Privacy Policy: platform/privacy-policy.md
• Records of Processing Activities: data-protection/records-of-processing-activities.md
• EU DSA Annex: annex/regions/digital-services-act-eu.md
• AML/Sanctions Policy: aml-sanctions-policy.md
• Anti-Corruption Policy: anti-corruption-policy.md
• Annual Transparency Report: transparency/annual-transparency-report.md

13) Adoption note

This Policy was adopted effective 28 May 2026. Status: Program Launch Pending. The Policy takes full operational effect upon the launch of the Tanqory marketplace functionality. It will be reviewed at least annually and upon any material change to DSA Article 30, the AMLD framework, OFAC sanctions regulations, or Singapore CDSA. Material revisions will be published on this page with a revised effective date and version number.