ANTI-MONEY LAUNDERING (AML) POLICY
1. PurposeThis Anti-Money Laundering (AML) Policy outlines the procedures implemented by Farabuto OÜ (“DIPPONG”) to prevent money laundering, terrorist financing, fraud, sanctions violations, and other illicit financial activities.
The Company is committed to operating in compliance with applicable Estonian and European Union AML legislation and applies a risk-based approach proportionate to its business model.
The Company:
• Designs and sells limited-edition, made-to-order 18 karat gold jewelry
• Produces items only after confirmed customer reservation
• Does not maintain pre-produced inventory
• Does not trade bullion, scrap gold, or precious metal commodities
• Does not operate a resale or secondary market
• Does not conduct physical retail operations
• Does not accept cash payments
The Company’s activities are limited to direct-to-customer sales of finished design objects.
Standard Transaction Range
EUR 2,000 – EUR 12,000
High-Value Transaction (Full Collection Purchase)
Up to approximately EUR 40,000
Transactions exceeding EUR 10,000 may trigger enhanced internal review procedures.
Transactions in the high-value category automatically trigger enhanced due diligence measures as outlined below.
The Company operates on a deposit-based production model:
• A deposit secures allocation and initiates production
• The remaining balance must be paid prior to shipment
The Company does not offer installment plans at this stage.
Payments are accepted exclusively through regulated financial institutions.
The Company:
• Does not accept cash
• Does not accept cryptocurrency
• Does not accept anonymous payment instruments
• Does not use unregulated intermediaries
Payments must originate from a bank account in the name of the customer placing the reservation.
The Company does not accept payments from unrelated third parties without prior verification.
If discrepancies arise between the reservation identity and the payment origin, the Company may:
• Request additional documentation
• Suspend the transaction
• Refuse the order
All refunds are issued exclusively to the original payment method used by the customer.
The Company does not issue refunds to alternative accounts or third parties.
This policy is implemented to prevent misuse of the business as a vehicle for value transfer.
The Company collects the following minimum customer information:
• Full name
• Billing address
• Shipping address
• Email address
For transactions exceeding EUR 10,000, the Company may request:
• Government-issued identification
• Proof of address
• Additional documentation where risk factors are present
The Company reserves the right to decline transactions where satisfactory identification cannot be obtained.
For transactions approximating EUR 40,000 or exceeding internal thresholds:
The following measures are mandatory:
• Full government-issued photo identification
• Proof of address
• Payment via direct bank transfer only
• Manual management review prior to acceptance
• Confirmation that payment originates from an account in the customer’s name
Where deemed necessary, the Company may request information regarding source of funds.
No production or allocation shall commence until enhanced due diligence has been completed and approved.
The Company monitors for unusual or suspicious activity, including:
• Structured payments designed to avoid review thresholds
• Rapid successive high-value purchases
• Payment origin inconsistent with customer identity
• Requests involving high-risk or sanctioned jurisdictions
• Attempts to bypass identification procedures
Where suspicion arises, the Company may:
• Delay fulfillment
• Request additional documentation
• Refuse the transaction
• Report to competent authorities if legally required
The Company primarily serves customers within the European Union.
Orders involving sanctioned individuals, entities, or jurisdictions will be declined.
The Company complies with applicable EU sanctions regulations and may perform sanctions screening where appropriate.
The Company maintains records of:
• Customer identification data
• Reservation confirmations
• Invoices
• Payment confirmations
• Transaction history
Records are retained in accordance with applicable legal and accounting requirements.
Given the scale of operations, AML oversight is conducted directly by Company management.
Risk assessments are reviewed periodically and adjusted as the business evolves.
The Company acknowledges that the intrinsic value of gold jewelry creates elevated inherent risk.
However, the Company mitigates such risk through:
• No cash handling
• No anonymous transactions
• No bullion trading
• Direct identifiable customer relationships
• Controlled deposit model
• Refund-to-origin-only policy
• Enhanced due diligence for high-value transactions
• Manual review for exceptional sales
The overall AML exposure is assessed as moderate and appropriately managed through proportionate controls.