AML/CFT POLICY

ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY

Effective Date: August 30, 2026

MARKETRA CC LLC ("Marketra," "Company," "we," "us," or "our") is committed to maintaining reasonable and proportionate controls designed to prevent the misuse of its services for money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful financial activity.

This Policy describes the AML/CFT principles applied by Marketra in connection with its online digital marketplace, SaaS platform, technology services, and related payment activities.

1. COMPANY INFORMATION

MARKETRA CC LLC
Delaware Limited Liability Company

Principal Business Address:
1401 Pennsylvania Ave Suite 105A PMB 70849
Wilmington, Delaware 19806
United States

Website:
https://marketra.cc

Email:
info@marketra.cc

2. BUSINESS MODEL

Marketra operates an online digital marketplace and technology/SaaS platform offering lawful products and services, which may include:

Source code;

Software applications;

Website templates and themes;

Plugins and scripts;

UI kits;

Design assets;

Developer tools;

Digital resources;

SaaS products;

AI-enabled tools and services;

Technology-related services.

Marketra does not represent itself as a bank, money transmitter, cryptocurrency exchange, financial institution, or custodial wallet provider unless a separate licensed or legally authorized service is expressly introduced.

3. PURPOSE

The purpose of this Policy is to:

Reduce the risk that Marketra is used for financial crime;

Establish risk-based customer and transaction controls;

Identify suspicious activity;

Support sanctions compliance;

Define escalation procedures;

Establish record-keeping requirements;

Support cooperation with authorized payment and financial service providers.

4. RISK-BASED APPROACH

Marketra applies AML/CFT measures according to the nature and level of identified risk.

Relevant risk factors may include:

Customer location;

Business activity;

Transaction value;

Transaction frequency;

Payment method;

Ownership structure;

Source of funds concerns;

Sanctions exposure;

Unusual account activity;

Fraud indicators;

Product or service risk.

Higher-risk relationships may be subject to additional review.

5. CUSTOMER DUE DILIGENCE

Marketra may request information reasonably necessary to understand and verify a User or business counterparty.

Information may include:

Full legal name;

Date of birth;

Residential address;

Country of residence;

Business name;

Company registration information;

Government-issued identification;

Contact information;

Beneficial ownership information;

Payment information;

Purpose of transactions.

The amount of information requested will depend on applicable law, payment provider requirements, and the identified risk level.

6. BUSINESS CUSTOMER AND SELLER VERIFICATION

Where Marketra allows third-party Sellers or business customers, Marketra may request:

Certificate of incorporation or formation;

Registered address;

Business address;

Director or manager information;

Beneficial ownership details;

Tax or registration information;

Website information;

Description of business activities;

Source of funds information;

Supporting documents.

Marketra may decline onboarding where required information cannot be satisfactorily verified.

7. BENEFICIAL OWNERSHIP

Marketra may identify individuals who ultimately own or control a business customer or Seller.

Where appropriate, Marketra may collect:

Name of UBO;

Ownership percentage;

Voting rights;

Management control;

Identification documentation;

Residential address.

Marketra may request additional documentation where ownership is complex, indirect, or unclear.

8. ENHANCED DUE DILIGENCE

Enhanced Due Diligence ("EDD") may be applied where elevated risk is identified.

EDD may include:

Additional identity verification;

Additional business documents;

Source of funds review;

Source of wealth review;

Enhanced sanctions screening;

Additional transaction review;

Manual compliance approval;

Increased monitoring.

9. SANCTIONS SCREENING

Marketra does not knowingly provide services in violation of applicable economic or trade sanctions.

Marketra may screen Users, business customers, Sellers, counterparties, and transactions against relevant sanctions restrictions.

Where a potential match is identified, Marketra may:

Delay a transaction;

Request additional information;

Restrict the account;

Reject the transaction;

Terminate the relationship;

Cooperate with competent authorities where required.

10. POLITICALLY EXPOSED PERSONS

Where appropriate, Marketra may identify whether an individual is a politically exposed person ("PEP"), family member of a PEP, or close associate.

A PEP relationship does not automatically prohibit use of Marketra.

However, additional review may be applied where required by applicable law or risk considerations.

11. TRANSACTION MONITORING

Marketra may monitor transactions and account activity for unusual or potentially suspicious patterns.

Indicators may include:

Transactions inconsistent with normal account activity;

Sudden increases in transaction volume;

Unusual refund behavior;

Repeated payment failures;

Multiple payment instruments associated with unusual activity;

Transactions involving high-risk locations;

Attempts to disguise the true purpose of a payment;

Payment activity inconsistent with the stated business purpose;

Suspected stolen payment methods;

Fraudulent chargeback activity.

12. SOURCE OF FUNDS

Marketra may request information concerning the source of funds where reasonably required.

Supporting information may include:

Bank statements;

Payment processor statements;

Business invoices;

Sales records;

Contracts;

Financial statements;

Tax records;

Other reasonable evidence.

Marketra may reject or delay transactions where the source or purpose of funds cannot be reasonably explained.

13. SUSPICIOUS ACTIVITY

Potentially suspicious activity may be escalated internally for further review.

Depending on the circumstances, Marketra may:

Request additional documentation;

Restrict an account;

Suspend transactions;

Refuse a payment;

Terminate services;

Notify payment providers;

Cooperate with competent authorities where required by law.

Marketra will not knowingly assist Users in avoiding legitimate compliance controls.

14. FRAUD PREVENTION

Marketra may use technical, operational, and third-party controls designed to identify:

Stolen payment credentials;

Identity fraud;

Account takeover;

Chargeback abuse;

Fake accounts;

Transaction manipulation;

Other fraudulent behavior.

Accounts associated with suspected fraud may be restricted pending review.

15. RECORD KEEPING

Marketra may retain relevant AML/CFT and compliance records for the period reasonably necessary to:

Meet legal obligations;

Resolve disputes;

Support investigations;

Meet payment provider requirements;

Demonstrate compliance controls.

Records may include identity information, business information, transaction data, supporting documents, and compliance review records.

16. PAYMENT SERVICE PROVIDERS

Marketra may use third-party banks, payment processors, payment institutions, fraud prevention providers, or identity verification providers.

Such providers may conduct their own:

KYC;

AML;

Sanctions;

Fraud;

Transaction monitoring;

Payment risk controls.

Marketra may cooperate with reasonable compliance requests made by these providers.

17. PROHIBITED FINANCIAL ACTIVITY

Users may not use Marketra to:

Launder money;

Finance terrorism;

Evade sanctions;

Commit fraud;

Process payments unrelated to legitimate Platform activity;

Use stolen financial credentials;

Facilitate unlawful transactions;

Conceal the true beneficiary of funds;

Circumvent payment restrictions.

18. COMPLIANCE RESPONSIBILITY

The overall compliance responsibility of MARKETRA CC LLC rests with its authorized management.

The responsible person may oversee:

Policy implementation;

Compliance reviews;

Suspicious activity escalation;

Payment provider inquiries;

Record keeping;

Policy updates.

19. TRAINING AND AWARENESS

Persons performing relevant compliance, customer support, payment, Seller onboarding, or fraud prevention functions should understand the Company's AML/CFT requirements applicable to their responsibilities.

20. CONFIDENTIALITY

Information obtained during AML/CFT reviews will be handled in accordance with:

Applicable law;

Marketra's Privacy Policy;

Legitimate compliance requirements;

Security requirements.

Marketra may disclose relevant information where legally required or where necessary to cooperate with authorized payment or financial service providers.

21. POLICY REVIEW

Marketra may periodically review and update this Policy based on:

Changes in applicable law;

Changes in business activities;

Payment provider requirements;

Emerging financial crime risks;

Operational experience.

22. CONTACT

Questions regarding Marketra's AML/CFT Policy may be sent to:

MARKETRA CC LLC

Email: info@marketra.cc
Website: https://marketra.cc

Last Updated: August 30, 2026

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