Effective Date: 2025-04-09
Last Updated: 2026-07-07

1. Introduction

Monarch Avenue OÜ ("Monarch Avenue", "we", "our" or "us") is committed to conducting business with integrity and maintaining the highest standards of ethical conduct.

Although Monarch Avenue is not a financial institution or otherwise generally subject to anti-money laundering obligations applicable to regulated financial service providers, we recognise the importance of preventing our platform from being used for money laundering, terrorist financing, fraud, sanctions evasion, or other forms of financial crime.

This Anti-Money Laundering & Financial Crime Prevention Policy outlines the principles, controls and procedures we apply to reduce financial crime risks within our business operations.

2. Scope

This Policy applies to:

• Monarch Avenue OÜ;
• all directors, officers and employees;
• contractors acting on behalf of Monarch Avenue;
• business partners where applicable; and
• transactions conducted through our website and related services.

This Policy should be read together with our:

• Terms of Service;
• Privacy Policy;
• Refund Policy; and
• any other applicable internal compliance procedures.

3. Our Commitment

Monarch Avenue is committed to:

• operating lawfully and ethically;
• maintaining appropriate controls to detect and prevent financial crime;
• working only with reputable business partners where reasonably practicable;
• complying with applicable sanctions laws;
• cooperating with competent authorities where legally required; and
• continually improving our risk management practices.

4. Risk-Based Approach

We adopt a risk-based approach when assessing potential financial crime risks.

Factors considered may include:

• transaction value;
• payment method;
• geographic location;
• shipping destination;
• billing information;
• unusual purchasing patterns;
• repeated failed payment attempts;
• use of anonymising technologies where suspicious circumstances exist; and
• any other indicators suggesting elevated risk.

Transactions identified as presenting increased risk may be subject to additional review before acceptance or fulfilment.

5. Customer Information

To protect our customers and our business, we may collect information necessary to process orders, verify payments, prevent fraud and comply with applicable legal obligations.

Depending on the circumstances, this may include:

• customer name;
• billing address;
• delivery address;
• email address;
• telephone number;
• payment confirmation;
• order history; and
• other information reasonably necessary for fraud prevention.

We do not routinely perform identity verification for every customer but reserve the right to request additional information where circumstances reasonably require.

6. Payment Controls

Monarch Avenue does not provide banking or payment services.

Payments are processed through reputable third-party payment service providers that maintain their own anti-money laundering, fraud prevention and regulatory compliance programmes.

Where appropriate, we rely on the security measures implemented by our payment providers while maintaining our own internal transaction monitoring procedures.

7. Transaction Monitoring

We monitor orders for indicators of unusual or suspicious activity.

Examples may include:

• unusually large purchases;
• multiple high-value purchases within a short period;
• repeated payment failures;
• mismatched billing and shipping information;
• excessive refund requests;
• suspected account misuse;
• unusual purchasing behaviour inconsistent with normal consumer activity; or
• any transaction that reasonably appears designed to conceal its true nature.

Monitoring is conducted using a combination of automated systems and manual review where appropriate.

8. Sanctions Compliance

Monarch Avenue is committed to complying with applicable economic sanctions and trade restrictions imposed by competent authorities.

Where required by applicable law, we reserve the right to:

• refuse orders;
• suspend transactions;
• cancel purchases;
• restrict customer accounts; or
• decline to conduct business

where a transaction may violate applicable sanctions laws or export restrictions.

9. Fraud Prevention

Protecting customers from fraud is an essential part of our operations.

We implement commercially reasonable measures designed to reduce fraud, including:

• secure payment processing;
• encrypted communications;
• payment verification procedures;
• order risk assessments;
• monitoring for suspicious purchasing behaviour; and
• investigation of reported fraudulent activity.

Where fraud is reasonably suspected, orders may be delayed, cancelled or refused.

10. Suspicious Activity

If information available to Monarch Avenue reasonably suggests that an order or customer activity may involve fraud, money laundering, sanctions evasion or other unlawful conduct, we may:

• request additional information;
• delay order processing;
• cancel an order;
• refuse future transactions;
• suspend customer accounts where appropriate; and
• report matters to competent authorities where required by applicable law.

Nothing in this Policy obliges Monarch Avenue to complete a transaction that it reasonably believes may be unlawful.

11. Business Partners

We seek to work with suppliers, logistics providers and commercial partners that maintain appropriate professional and ethical standards.

Although Monarch Avenue does not control the internal compliance programmes of independent businesses, we endeavour to establish relationships with reputable organisations whose practices align with our own standards of integrity.

12. Record Retention

Business records relating to orders, payments and compliance activities are retained for the periods required by applicable law or for as long as reasonably necessary to:

• comply with legal obligations;
• resolve disputes;
• prevent fraud;
• support investigations; or
• enforce our contractual rights.

13. Data Protection

Any personal information processed under this Policy will be handled in accordance with our Privacy Policy and applicable data protection legislation, including the General Data Protection Regulation (GDPR) where applicable.

Information is processed only where there is a lawful basis for doing so.

14. Employee Responsibilities

Employees responsible for customer service, compliance or operational functions are expected to:

• act honestly and ethically;
• report suspected financial crime internally;
• protect confidential information;
• follow internal compliance procedures; and
• cooperate with lawful investigations.

Failure to comply with applicable internal policies may result in disciplinary action.

15. Reporting Concerns

Employees, business partners or other parties who become aware of suspected unlawful conduct involving Monarch Avenue are encouraged to report their concerns promptly through the appropriate internal reporting channels.

Reports will be handled confidentially to the extent permitted by law.

16. Cooperation with Authorities

Monarch Avenue will cooperate with competent regulatory, law enforcement and judicial authorities where required by applicable law.

Such cooperation may include the provision of information or records where legally requested.

17. Policy Review

This Policy will be reviewed periodically to ensure it remains appropriate for the nature, size and risk profile of Monarch Avenue's business.

We reserve the right to amend this Policy at any time to reflect changes in applicable laws, regulations or business operations.

18. Contact

Questions regarding this Policy may be directed to:

Monarch Avenue OÜ

Email: info@monarch-avenue.com

Registered Address: Narva mnt 5, Kesklinna linnaosa
Tallinn 10117, Estonia

Company Registration Number: 17450492