Anti-Money Laundering (AML) Policy

Last updated: June 22th, 2025

1. Purpose and Scope

This AML Policy outlines the principles and procedures adopted by Horshare, a platform legally managed by MR Group S.r.l. (hereinafter, “Horshare”, “we”, or “the Platform”) to prevent money laundering, terrorist financing, and other financial crimes in compliance with applicable Italian law, the EU AML Directives, and FATF recommendations.

Horshare provides a platform for the tokenization and management of fractional ownership in racehorses using non-fungible tokens (NFTs) on blockchain technology. While Horshare is not a registered VASP (Virtual Asset Service Provider), all AML-related obligations are delegated to certified third-party providers.

2. Jurisdicrion and Legal Basis

This policy is governed by the laws of Italy. Horshare implements this AML framework in alignment with the EU’s 6th Anti-Money Laundering Directive (6AMLD), Italian Legislative Decree No. 231/2007, and FATF guidelines.

3. Third-Party Compliance Provider

To ensure robust AML and customer due diligence processes:

    • KYC and KYB procedures for all users (individuals and legal entities such as associations and syndicates) are conducted by Zyphe, an external compliance provider with expertise in identity verification and risk screening.

    • Fiat-to-crypto on-ramp services are provided by Transak, which performs its own KYC and AML checks in compliance with regulatory standards.

4. User Onboarding Requirements

All users are required to undergo identity verification before accessing or using any of the following features:

    • Participation in token-gated areas of the Platform.

    • Access to token-related information and governance tools (e.g., voting).

    • Execution and finalization of horse co-ownership transfers.

The onboarding process includes:

    • KYC for individuals.

    • KYB for entities, with identification of Ultimate Beneficial Owners (UBOs).

    • AML screening against sanctions, PEPs, and adverse media lists.

5. Secondary Market & Peer-to-Peer Transferse

Buyers of tokens acquired via secondary market channels or private transactions must complete KYC verification prior to exercising any token-related rights or benefits on the Platform.

Ownership transfers of fractional shares in horses will only be recognized on the Platform once the new holder is fully verified.

6. Non-Custodial Wallet Environment

All tokens are held in non-custodial wallets controlled by users. While Horshare does not maintain custody over user assets, KYC/KYB remains a prerequisite for utilizing the Platform’s services.

7. Ongoing Monitoring and Periodic Review

All verified users are subject to periodic reviews of their identity and risk profile. Zyphe provides ongoing monitoring of sanctions and risk exposure. Users may be asked to re-verify their identity upon expiration of documentation, material changes, or as part of routine audits.

8. Enhanced Due Diligence (EDD)

Transactions exceeding USD 50,000 (or equivalent in stablecoins or cryptocurrencies) trigger enhanced due diligence procedures, including:

    • Additional documentation.

    • Source of funds declaration.

    • Manual review of the transaction context.

9. High-Risk Jurisdictions and Sanctions

Horshare does not accept users from jurisdictions classified by FATF as high-risk or under increased monitoring. IP detection, geolocation, and document-based screening are used to enforce this restriction.

10. Suspicious Activity and Reporting

Horshare reserves the right to suspend or terminate user access where suspicious activity is detected or reported by its compliance providers. Zyphe and Transak autonomously report suspicious transactions to competent authorities where legally required.

11. Right to Restric or Terminate Access

Horshare may restrict or terminate user accounts without prior notice in the event of:

    • Failure to complete KYC/KYB procedures.

    • Refusal to provide additional information under EDD.

    • Use of the platform in a manner inconsistent with this AML Policy.

12. Data Protection

User data processed for KYC/KYB and AML purposes is handled in accordance with the EU General Data Protection Regulation (GDPR) and Italian privacy law. For further information, please refer to our [Privacy Policy].

13. Review of Policy

This AML Policy is reviewed regularly and updated as necessary to reflect changes in law, regulation, or operational practices.