KYC & Compliance Policy

1. Purpose and scope

This Policy explains the identity, screening and monitoring checks we apply when you buy an AYNI UNIT collectible, why we apply them, what we will ask you for, and what happens if a check cannot be completed.

Phoebe Partners Limited sells collectible items. High-value collectibles are attractive to anyone looking to move money quietly, and we take that seriously. This Policy sets out the customer due diligence framework we operate. It applies to every buyer, and to every seller receiving proceeds from a Marketplace sale.

2. Why we apply dealer standards

We are a dealer in collectibles, not a financial institution. AYNI UNIT pays nothing to its owners and is not a financial product of any kind, so the rules governing banks and payment firms do not apply to us.

The framework that does fit our activity is the one the European Union applies to the art and high-value goods trade. Directive (EU) 2018/843 brought persons trading in works of art within scope where a transaction, or a series of linked transactions, reaches EUR 10,000 or more. Cyprus implements this through the Prevention and Suppression of Money Laundering and Terrorist Financing Laws of 2007 to 2021 (Law 188(I)/2007, as amended).

Sanctions obligations are different: they apply to everyone, at every value, with no threshold at all. We screen every buyer accordingly.

3. Our principles

• Proportionate. A $30 piece and a $50,000 piece do not carry the same risk, and we do not treat them the same way. Checks scale with value and risk.
• Know who we are dealing with. We do not complete or continue a relationship where we cannot satisfy ourselves who the customer is.
• Continuous, not a one-off gate. We monitor throughout the relationship and refresh information periodically.
• Documented. Every check, decision and escalation is recorded and retained.
• Independent. A designated Compliance Officer owns this Policy, reports to the board, and has authority to block or exit any relationship without commercial override.

4. When checks apply

Purchases are aggregated. Splitting one large purchase into several smaller ones does not avoid the threshold, and deliberate structuring of that kind is itself a reportable indicator.

5. What we ask for

Where full due diligence applies, we collect and verify:

Checks are carried out through a regulated third-party verification provider. Your documents go directly to that provider over a secure channel. Handling of this data is described in our Privacy Policy.

6. Enhanced checks

We go further where the risk is higher. Triggers include: a purchase or linked purchases at or above EUR 50,000; a buyer, family member or close associate who is a politically exposed person; residence or payment origin connected to a high-risk or increased-monitoring jurisdiction; a payment inconsistent with what we know about the buyer; reluctance to provide information; or an adverse media match.

Enhanced measures may include:

• documentary evidence of the source of the money — payslips, employment contract, audited accounts, sale-of-asset documents, inheritance or gift documentation, or tax filings;
• evidence of source of wealth — how the buyer's overall wealth was built;
• certified or notarised copies of identity documents;
• senior management approval before the sale proceeds;
• closer monitoring and more frequent refresh thereafter.

7. Screening

Every buyer is screened at the point of order and re-screened on an ongoing basis against:

• consolidated sanctions lists of the United Nations Security Council, the European Union, the United Kingdom (OFSI) and the United States (OFAC), including designations based on ownership or control;
• politically exposed person data, covering domestic and foreign PEPs, family members and known close associates;
• law enforcement and regulatory watch lists;
• adverse media, focused on financial crime, fraud and corruption.

A confirmed sanctions match means the relationship is blocked, any funds held are frozen, and the matter is reported to the competent authority. We do not refund where refunding would itself breach sanctions. Every potential match is reviewed by a person before any adverse decision is taken, and you may ask for that review.

8. Who we cannot accept

• anyone under 18;
• residents of countries subject to comprehensive sanctions, or of any country where the sale would be unlawful or would need an authorisation we do not hold;
• anyone on an applicable sanctions list, or an entity owned or controlled by such a person;
• anyone who refuses to provide required information, or whose information we find to be false;
• anyone paying with money we reasonably believe is not their own or is of unlawful origin;
• anyone paying from an account in a different name;
• anyone using anonymising services to disguise where they are.

The restricted country list is applied at checkout, reviewed regularly, and may change without notice.

9. Ongoing monitoring

We watch for patterns that do not fit an ordinary collector, including:

• payment origin inconsistent with the declared country of residence;
• multiple accounts sharing an address, device, payment instrument or other identifier;
• a purchase followed immediately by a request to refund to a different destination;
• rapid buying and reselling with no apparent collecting interest;
• orders sized just below a threshold, repeated over time;
• buying and selling between accounts under common control, which can move value while appearing to be trade;
• a sudden, unexplained change in the size or frequency of purchases.

Where an indicator triggers, the account is escalated to the Compliance Officer, activity may be paused pending review, and further information may be requested.

10. Marketplace sales

10.1 Resale between collectors is where value moves most easily, so it receives particular attention.

10.2 Identity verification is required before we pay out proceeds of any Marketplace sale, at any value, without exception.

10.3 Proceeds are paid only to an account in the seller's own verified name. We do not pay third parties.

10.4 Sales at a price far above or far below anything comparable are reviewed before proceeds are released, because mispricing is a classic way to move value between two cooperating parties.

10.5 We may decline to complete a transfer, or hold proceeds, where either side is under review.

11. Reporting obligations

Where the Compliance Officer knows or suspects, or has reasonable grounds to suspect, that funds are the proceeds of criminal conduct or relate to terrorist financing, a report is filed with MOKAS, the Unit for Combating Money Laundering of the Republic of Cyprus.

12. Record keeping

Due diligence records, supporting documents, screening results, transaction records and internal decisions are kept for five years from the end of the relationship or the date of the transaction, and longer where a competent authority directs. Records are kept in a form admissible in legal proceedings and handled in line with our Privacy Policy.

The ownership Register itself is kept for as long as the Collection exists, so that provenance can be evidenced. That is a separate record from due diligence material and is described in the Privacy Policy.

13. If checks cannot be completed

• Before an order is confirmed — the order is declined and anything taken is refunded in full to the original payment method, unless refunding would itself breach sanctions or another legal restriction.
• After an order is confirmed — you keep the piece and it stays recorded in your name. Marketplace listing and any payout of proceeds are suspended until verification is complete.
• Where verification is refused or fails — the account is restricted and we may end the relationship under the Terms & Conditions. Your Units remain yours.
• Where a sanctions match is confirmed — funds are frozen and the matter reported. They are released only on the instruction of the competent authority.

14. Governance and training

The Compliance Officer owns this Policy, oversees screening and monitoring, files reports, and reports to the board at least annually. Staff who deal with customers receive anti-money-laundering training at induction and at least annually thereafter, covering the indicators in section 9 and how to escalate. This Policy is reviewed at least annually, and whenever the applicable legal framework changes.