OVERTAKE

Anti-Money Laundering (AML) Policy

OVERTAKE LABS PTE. LTD.

Measures and procedures to detect, prevent, and mitigate illicit financial activities on the OVERTAKE Market platform.

1. Purpose

This Anti-Money Laundering Policy ("AML Policy") sets out the measures and procedures adopted by OVERTAKE LABS PTE. LTD. ("OVERTAKE", "we", "our", or "us") to detect, prevent, and mitigate money laundering, fraud, and other illicit financial activities on the OVERTAKE Market platform (the "Platform").

This policy forms part of the overall framework governing use of the Platform and should be read together with the Terms of Service and Seller Acceptable Use Policy ("Seller AUP").

2. Scope

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All users of the Platform, including buyers and sellers
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All transactions conducted through the Platform
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Internal processes related to monitoring user activity and maintaining platform integrity

3. Risk-Based Approach

OVERTAKE applies a risk-based approach to identifying, monitoring, and addressing potential financial crime risks.

Risk controls are proportionate to the nature of user activity, with enhanced controls applied to higher-risk activities, including seller transactions.

4. Customer Due Diligence (CDD)

4.1 Seller Onboarding

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Sellers are subject to identity and business verification processes as part of onboarding
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Such verification may be conducted through OVERTAKE-designated payment or service providers
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Only verified accounts are permitted to receive payments on the Platform

4.2 Buyer Controls

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Buyers are required to create accounts using verified email credentials
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Platform-level monitoring is applied to detect and review suspicious buyer behavior

4.3 Enhanced Due Diligence (EDD)

OVERTAKE may apply enhanced due diligence measures where user activity presents elevated risk.

Such situations may include:

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Users transacting from higher-risk jurisdictions
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Transaction patterns that significantly deviate from expected behavior
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Accounts exhibiting unusual volume or frequency of activity
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Potential matches against sanctions or internal risk indicators

Enhanced measures may include additional verification, increased monitoring, or restrictions on account activity.

5. Transaction Monitoring

OVERTAKE applies transaction monitoring measures, based on a risk-based approach, to identify potentially suspicious activity.

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High-value transaction patterns
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Unusual transaction frequency (velocity checks)
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Suspicious account behavior (e.g., multiple accounts, abnormal usage patterns)
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Transactions involving high-risk or restricted jurisdictions

Monitoring measures are subject to ongoing refinement based on evolving risk patterns.

Flagged transactions are subject to internal review and assessment.

6. Sanctions and Restricted Activities

OVERTAKE enforces restrictions on:

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Transactions involving sanctioned countries or regions
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Users identified through internal or external risk indicators

Activities prohibited under the Seller Acceptable Use Policy are also subject to monitoring and enforcement under this AML framework.

OVERTAKE reserves the right to restrict or block access to the Platform based on risk assessment.

7. Suspicious Activity Handling

Where potentially suspicious activity is identified:

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The relevant transaction or account may be flagged through monitoring processes
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Internal review may be conducted by designated personnel
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OVERTAKE may take appropriate actions, including:
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Temporary restriction of accounts
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Blocking or reversing transactions where feasible
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Requesting additional user verification

Where appropriate, OVERTAKE may escalate matters to relevant partners or service providers.

8. Record Keeping

OVERTAKE maintains records of:

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User account information
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Transaction history
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Monitoring flags and internal review outcomes

Records are retained for a reasonable period in accordance with operational requirements and good practices.

9. Governance and Responsibility

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OVERTAKE maintains internal responsibility for monitoring and enforcing this AML Policy
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Certain verification and payment-related functions may be supported by third-party service providers
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OVERTAKE does not take custody of user funds unless explicitly stated otherwise
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This policy is reviewed and updated periodically

10. Policy Updates

OVERTAKE may update this AML Policy from time to time. Updated versions will be published on the Platform with the revised effective date.