Anti-Money-Laundering Policy & Procedures

Larevv, LLC ("Larevv") is committed to conducting its business with integrity and in compliance with applicable anti-money-laundering ("AML") and counter-terrorist-financing ("CTF") laws and regulations. Larevv maintains a risk-based AML program reasonably designed to detect, deter, and prevent the use of its business for money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime.

This policy applies to all Larevv transactions, customers, consignors, suppliers, employees, contractors, and representatives. It governs the purchase, sale, consignment, and acquisition of goods through Larevv, and all associated payments. Larevv expects all parties it transacts with to comply with applicable AML and sanctions laws.

Larevv designs its AML program to align with applicable laws and recognized standards, which may include, where applicable, the U.S. Bank Secrecy Act and USA PATRIOT Act, regulations administered by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), applicable European Union anti-money-laundering directives and regulations, and other international AML and sanctions standards relevant to Larevv's activities and the jurisdictions in which it operates.

Larevv designates a Compliance Officer responsible for the development, implementation, oversight, and ongoing maintenance of this AML program. The Compliance Officer's responsibilities include maintaining the program's policies and procedures, overseeing customer due diligence and screening, reviewing escalated transactions, ensuring required reporting, coordinating with authorities, and arranging staff training and periodic review.

Larevv applies a risk-based approach proportionate to the money-laundering and sanctions risks associated with its business, including the high-value nature of certain goods. Larevv assesses risk by reference to factors such as transaction value, payment method, customer and geographic risk, shipping destination, and transaction patterns, and applies controls commensurate with the level of risk identified.

Larevv conducts customer due diligence appropriate to the risk of a transaction. Larevv may require identity verification, billing and shipping verification, payment-source confirmation, and supporting documentation, and may decline, delay, or cancel any transaction where due diligence cannot be satisfactorily completed.

For higher-risk transactions — including those involving elevated values, unusual patterns, higher-risk jurisdictions, or other risk indicators — Larevv may apply enhanced due diligence. This may include additional identity and source-of-funds verification, additional documentation, senior review, or other measures before a transaction proceeds.

Larevv screens customers and transactions against applicable sanctions and watch lists, which may include lists maintained by OFAC and other relevant authorities.

Where relevant and required, Larevv considers whether a customer is a politically exposed person (PEP) or otherwise presents heightened risk, and may apply enhanced due diligence to such transactions in accordance with a risk-based approach.

Larevv requires that payment be made by the customer using a payment instrument held in the customer's own name. Third-party payments may be declined. Larevv may request information regarding the source of funds for higher-value transactions.

Larevv monitors transactions for indicators of suspicious or unusual activity, including patterns inconsistent with normal purchasing behavior, structuring or value-splitting, mismatched identity or payment details, rapid resale indicators, or other red flags. Specific monitoring criteria and thresholds are maintained internally and are not published.

Transactions or conduct identified as suspicious are escalated to the Compliance Officer for review. Where required by applicable law, Larevv reports suspicious activity to the appropriate authorities and may delay, decline, freeze, or cancel a transaction pending review.

Larevv prohibits, and will not knowingly facilitate, any of the following:

Larevv maintains records of customer verification, transactions, screening results, and related compliance documentation for the period required by applicable law (generally at least five (5) years), and makes such records available to authorities where lawfully required.

Larevv provides AML and sanctions awareness training to relevant personnel appropriate to their roles, so that staff are able to recognize and escalate potential red flags and understand their obligations under this policy.

Larevv periodically reviews and tests its AML program to assess its adequacy and effectiveness, and updates its policies, procedures, and controls in response to findings, regulatory developments, and changes in its risk profile.

Larevv cooperates with law enforcement, regulators, and financial institutions in connection with the prevention, detection, and investigation of money laundering, terrorist financing, fraud, and other financial crime, and responds to lawful requests in accordance with applicable law.

By transacting with Larevv, customers, consignors, and suppliers agree to provide accurate information and any verification reasonably requested, and acknowledge that Larevv may decline, delay, or cancel any transaction, and may refund or withhold a transaction, where necessary to comply with this policy or applicable law. This policy operates together with Larevv's Terms of Service.

This policy is maintained under the authority of Larevv's Compliance Officer and is reviewed and updated periodically and as required by changes in applicable law or Larevv's risk profile. Detailed internal procedures supporting this policy are maintained separately and are not published.