Anti-Money Laundering and KYC Policy

Last updated: October 6, 2026 · Version 1.1

7 Baas Limited ("7Baas") is committed to preventing its marketplace, brokerage and settlement services from being used for money laundering, terrorist financing, sanctions evasion, fraud or other financial crime. This page summarises the policy that applies to all users of the Platform.

1. Legal framework

7Baas designs its controls with reference to the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Sanctions and Anti-Money Laundering Act 2018 and the Criminal Finances Act 2017, together with guidance issued by UK authorities. Where a transaction involves another jurisdiction, we also take its requirements into account.

2. Responsibility

Our Money Laundering Reporting Officer (MLRO) is responsible for this policy, for assessing unusual activity and for reporting suspicions to the National Crime Agency. The policy is approved by our board and reviewed at least once a year, and whenever laws or our services change.

3. Risk-based approach

We assess the money laundering, terrorist financing and sanctions risk of each user and each Deal, taking into account the customer, its ownership and control, the countries involved, the type of company or licence being sold, the value of the transaction, the payment method and the source of funds. The level of checks depends on that assessment.

4. Customer due diligence

Individuals. We verify identity using an identity verification provider: an official identity document, a liveness check and face matching. We may also verify residential address.

Companies and other entities. We verify the legal name, registration number, registered address and status, and identify the directors and the ultimate beneficial owners — any individual who owns or controls, directly or indirectly, more than 25% of the shares or voting rights, or otherwise exercises control. We verify the identity of beneficial owners and of the individual acting for the entity, and confirm that person's authority.

When checks are carried out: - Buyers — before signing the NDA and accessing the Deal Room, and in any case before any money is paid to the Escrow Account. - Sellers — before a Listing is published, including evidence that the Seller owns or is authorised to sell the target company, and information on the target company's ownership and control. - Payers — before we accept a payment, the payer must be the verified customer.

We do not open or maintain anonymous accounts or accounts in fictitious names.

5. Enhanced due diligence

We apply enhanced due diligence where risk is higher, including: - politically exposed persons, their family members and close associates; - customers or transactions connected with a high-risk third country identified by the UK, or with a jurisdiction subject to a call for action by the Financial Action Task Force; - complex, unusual or opaque ownership structures, nominee arrangements or bearer shares; - large transactions, or transactions inconsistent with the customer's profile; - payments in crypto-assets.

Enhanced due diligence may include evidence of source of funds and source of wealth, additional documents, senior management approval and closer ongoing monitoring.

6. Source of funds

Before money is deposited to the Escrow Account, the Buyer must explain and, where we request it, evidence where the money comes from. Deposits must be made by bank transfer from an account in the Buyer's own name.

7. Sanctions

We screen users, beneficial owners, directors, target companies and counterparties against the UK sanctions list (OFSI), and the sanctions lists of the United Nations, the European Union and the United States (OFAC), at onboarding and on an ongoing basis. We do not deal with sanctioned persons or with persons owned or controlled by them, and we do not facilitate transactions involving comprehensively sanctioned countries or territories.

8. Payments

• No cash, money orders or third-party payments are accepted.
• Escrow deposits are accepted only by bank transfer from an account in the Buyer's own name; crypto-assets are not accepted for escrow deposits.
• Invoices payable to 7Baas may be paid by bank transfer or, where offered, in USDT on the TRON network (TRC-20). Crypto payments are reviewed manually before they are confirmed. We may ask for proof of wallet ownership and may screen the sending address and transaction history.
• Releases and refunds are paid only to verified accounts in the name of the entitled party.

9. Ongoing monitoring

We monitor Deals and payments for activity that is unusual or inconsistent with what we know about the customer, and we refresh customer information periodically and when circumstances change. Users must tell us promptly about changes in ownership, control or identity information.

10. Refusal and termination

We may refuse to onboard a user, publish a Listing, open or continue a Deal, accept a payment or release funds where we cannot complete due diligence, where information is false or incomplete, or where we suspect financial crime. In those circumstances we may be legally prohibited from explaining our reasons.

11. Reporting

Staff report any knowledge or suspicion of money laundering or terrorist financing to the MLRO, who decides whether to make a suspicious activity report to the National Crime Agency and, where required, to seek a defence against money laundering before proceeding. We do not tell anyone that a report has been or may be made.

12. Record keeping

We keep customer due diligence records, screening results and transaction records for at least 5 years after the end of the business relationship or the completion of the transaction, and longer where required by law.

13. Training

Everyone who works on the Platform receives training on this policy, on recognising suspicious activity and on their reporting obligations, when they join and at least once a year.

14. Your obligations

You must provide accurate and complete information, respond promptly to requests for information, tell us about relevant changes, and not use the Platform for any unlawful purpose. Providing false information is a breach of our Terms of Use and may be reported to the authorities.

15. Contact

Questions about this policy can be sent to admin@7baas.com with "Compliance" in the subject line.