1. Purpose and scope

This Law Enforcement Playbook establishes the internal standards and procedures applied by the Platform to detect, assess, respond to, and cooperate with authorities in relation to suspected money laundering, terrorist financing, sanctions violations, fraud, and other serious legal or regulatory breaches occurring through use of the Platform.

This Playbook governs internal Platform actions only and does not create rights, remedies, or expectations for Vendors, Buyers, or third parties.

2. Platform role and limitations

The Platform operates solely as an intermediary marketplace and is not the seller of record, buyer, payment service provider, logistics provider, or guarantor of transactions.

The Platform does not provide legal, regulatory, or compliance advice to Vendors or Buyers and does not assume responsibility for their compliance with applicable laws.

3. Transaction monitoring and risk indicators

The Platform may monitor transactions, accounts, listings, content, payments, and activity patterns for the purpose of detecting indicators of elevated risk, including but not limited to:

1. Unusual transaction sizes, including single or aggregated transactions exceeding internally defined thresholds.

2. Repetitive high value transactions inconsistent with an eShop’s stated business profile.

3. Patterns indicative of layering, structuring, or circular transactions.

4. Repeated chargebacks, disputes, or payment reversals.

5. Use of false, misleading, incomplete, or inconsistent identity or business information.

6. Listings or products associated with restricted, prohibited, or sanctioned goods or parties.

4. Information requests and verification

Where the Platform identifies elevated risk or potential non compliance, it may, at its sole discretion:

1. Request additional information, documentation, or clarification from a Vendor or Buyer.

2. Require confirmation of licensing, corporate authority, beneficial ownership, or source of funds.

3. Suspend settlement or access pending review. Failure to provide requested information within the timeframe specified by the Platform constitutes grounds for enforcement action.

5. Sanctions screening and restrictions

The Platform may restrict or prohibit access, transactions, settlements, or withdrawals where a user, transaction, product, or counterparty is reasonably suspected to be subject to applicable sanctions, embargoes, or trade restrictions.

The Platform is not required to disclose the basis of sanctions related actions where disclosure is restricted by law or would compromise regulatory cooperation.

6. Reporting and cooperation with authorities

The Platform may report information, activity, and records to competent authorities where required by law or where the Platform determines that reporting is appropriate to mitigate legal, regulatory, or reputational risk.

The Platform may cooperate with law enforcement, regulators, courts, and other authorities by providing records, data, and technical assistance to the extent permitted by law.

Such cooperation may occur without prior notice to affected Vendors or Buyers where legally permitted.

7. No obligation to continue service

The Platform has no obligation to maintain accounts, eShops, listings, payments, or settlements where AML, sanctions, or serious compliance concerns are identified.

All actions are taken on a risk management basis and do not constitute a determination of guilt or liability.