RABBIT.IO AML/KYC Policy

Last Updated: November 20, 2025

This AML/KYC Policy outlines the procedures Rabbit.io (“Rabbit”, “Platform”, “Company”, “we”, “us”, or “our”) follows to prevent money laundering, terrorist financing, and other illicit activities when users interact with our crypto-to-crypto non-custodial exchange platform. This policy explains the measures we use to detect unusual activity, meet applicable regulatory obligations, and maintain a secure and compliant environment.

1. DEFINITIONS

   For the purposes of these AML/KYC Policy, the following terms shall have the meanings set forth below. All definitions apply equally to singular and plural forms, and all grammatical variations thereof.

   1. "Platform" refers to the web-based interface operated by the Company, accessible at https://rabbit.io, including all associated subdomains, APIs, software modules, and any other services or technologies provided by the Company that enable Users to perform crypto-asset exchange transactions.
   2. "User" refers to any natural or legal person who accesses or uses the Platform, regardless of whether such person initiates a transaction. Where applicable, “you” or “your” shall refer to the User.
   3. "Crypto Asset" (also referred to as "cryptocurrency", "token", or "digital asset") means a digital representation of value that is based on or issued via blockchain technology and is capable of being transferred, stored, or traded electronically. This includes, but is not limited to, Bitcoin (BTC), Ethereum (ETH), and other tokens or coins that are not classified as securities under applicable laws.
   4. "Exchange" or "Swap" refers to a transaction facilitated through the Platform, whereby the User submits one type of Crypto Asset in exchange for another, either via the Company’s proprietary exchange system or through integrated Third-Party Providers.
   5. "Non-Custodial Service" means a service model where the Company does not store, hold, or maintain control over any User funds, wallets, or private keys, except for temporary possession strictly required to facilitate a specific transaction or perform compliance-related reviews.
   6. "AML/KYC Procedures" means Anti-Money Laundering and Know Your Customer screening measures implemented by the Company or its Third-Party Providers to ensure compliance with applicable financial regulations.
   7. "Restricted Jurisdictions" means any country, territory, or region where the use of the Platform is prohibited by law or by decision of the Company, including but not limited to jurisdictions sanctioned by the United Nations, European Union, U.S. Department of Treasury (OFAC), or other relevant authorities.
   8. "Service" or "Services" collectively refers to all functionalities, transactions, exchange mechanisms, compliance processes, customer support tools, APIs, and other related features made available to Users through the Platform.

2. AML, SANCTIONS, AND COMPLIANCE REQUIREMENTS

   The Platform is committed to operating in full compliance with international standards for Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and sanctions enforcement, despite offering a non-custodial and registration-free service. The following provisions apply to all Users of the Platform and form a material part of these Policy.

   1. Regulatory Position and Risk-Based Approach. Although the Platform does not collect traditional Know-Your-Customer (KYC) information at onboarding, the Company reserves the right to implement enhanced due diligence (EDD) procedures in specific circumstances where required by law or where the Company identifies elevated transactional risks. Such procedures may include, without limitation, temporarily holding funds, requesting additional verification, or declining service.
   2. The Company uses a risk-based approach aligned with the recommendations of the Financial Action Task Force (FATF) to assess transactions in real time. Blockchain analytics tools may be employed to screen wallet addresses, transaction histories, or counterparties to detect potential involvement in illicit activities, including but not limited to: ransomware, darknet marketplaces, sanctioned entities, fraud or scam operations, terrorism financing.
   3. Conditional Identity Verification (KYC). In accordance with our AML risk management framework, the Platform may require Users to undergo identity verification (KYC) if a transaction is flagged with a high-risk score based on our automated screening procedures. Such verification may be conducted through trusted third-party KYC providers and may include document-based or biometric checks, in compliance with applicable data protection regulations (e.g., GDPR, CCPA). Refusal to complete such verification may result in delayed execution or refund of the transaction. In some cases, the Platform is unable to issue refunds without passing KYC verification.
   4. Prohibited Use by Sanctioned Persons or Jurisdictions. Users may not access or use the Platform if they are:
      1. subject to international sanctions (including but not limited to sanctions imposed by the United Nations, U.S. Department of the Treasury – OFAC, European Union, or UK HM Treasury),
      2. a citizen or resident of, or accessing the Service from, any country or territory subject to comprehensive sanctions (including but not limited to North Korea, Iran, Syria, Cuba, Crimea, Donetsk, or Luhansk),
      3. acting on behalf of any such persons or entities.
      4. citizens and residents of the United States of America.
      5. residents from countries where usage of cryptocurrency or usage of Service is forbidden by applicable law.
      By using the Platform, you affirm and warrant that you are not located in a restricted jurisdiction, are not a sanctioned individual or entity, and are not using the Services to conduct or facilitate any transaction with or for any such persons.
   5. Transaction Review and Blocking Rights. The Company reserves the right, in its sole discretion and without prior notice, to:
      1. delay or suspend the processing of any transaction that is flagged for potential AML or sanctions concerns;
      2. freeze assets temporarily while further review is conducted;
      3. reject transactions deemed suspicious, high-risk, or in violation of applicable law;
      4. report activity to competent financial intelligence units (FIUs) or law enforcement authorities, where required or appropriate.
      In such cases, the Company shall not be liable for delays, losses, or any inability to complete the exchange arising from such compliance actions.
   6. User Representations and Cooperation Obligations. By using the Platform, you represent and warrant that:
      1. you are the lawful owner and ultimate beneficiary of the crypto assets involved in the exchange;
      2. all funds used are of legal origin and not associated with illicit conduct;
      3. you will cooperate with the Company in good faith if additional information or documents are required for legal or compliance reasons;
      4. you acknowledge that the Company is under no obligation to complete a transaction if it would result in a breach of law or regulatory standards.
   7. No Circumvention of Controls. Users are strictly prohibited from attempting to bypass, obfuscate, or otherwise manipulate the Platform's AML screening mechanisms or technical infrastructure, including by:
      1. initiating multiple transactions to avoid threshold-based detection,
      2. using privacy-enhancing tools (e.g., mixers, tumblers, or anonymizing protocols),
      3. submitting altered, falsified, or incomplete information.
   8. Any attempt to circumvent controls constitutes a material breach of these Terms and may result in immediate denial of access, permanent blocking of transactions, and referral to relevant authorities.

3. AML Compliance Philosophy

   1. While the Platform currently operates on a non-custodial, registration-free basis, the Company is committed to upholding core principles of anti-money laundering (AML) compliance. Transactions may be screened through third-party AML tools, and cooperation with regulatory authorities may be initiated in cases involving suspicious activity, as outlined in Section 9 (Legal Cooperation and Enforcement).

4. Relationship to the Terms of Service

   1. This AML/KYC Policy is a direct excerpt of the Rabbit.io Terms of Service (“Terms”) that has been placed in a separate document solely for convenience and ease of reference. It does not replace, modify, or expand upon the Terms in any way. The full and legally binding version of our AML/KYC obligations and requirements is contained within the Terms of Service, available at: https://rabbit.io/terms-of-use.
   2. In any legal or interpretative context, the Terms of Service shall take priority and remain the primary governing agreement. If any discrepancies arise between this document and the Terms, the wording and intent of the Terms of Service shall prevail.