AML/CTF Policy

1. Purpose and scope

This Anti-Money Laundering and Counter-Terrorism Financing ("AML/CTF") Policy applies to all activities of the Handsome marketplace (handsomemakers.com), operated by Michael Balleroni — Italian Sole Proprietorship, VAT ID 02871720419, registered office at Via Ciro Menotti 184, Int. 3, 61122 Pesaro (PU), Italy (the "Platform" or "Handsome").

The Platform adopts a Risk-Based Approach compliant with Italian Legislative Decree 231/2007 (transposing EU Directive 2015/849 — 4AMLD) and amendments, and EU Directive 2018/843 (5AMLD).

2. Operating model

Handsome operates as an experiential marketplace facilitator. Payments are entirely delegated to licensed processors (Stripe Inc. and PayPal Europe), both subject to AML/CTF obligations in their respective jurisdictions:

• Stripe: PCI-DSS Level 1, US Money Transmitter and EU EMI license, performs full KYC/KYB on sub-merchants (artisans) before onboarding.
• PayPal Europe: Luxembourg EMI banking license (CSSF), Partner Referrals performs KYC on sub-merchants via OAuth onboarding.

The Platform never holds funds belonging to customers or artisans: transactions are atomic and funds flow directly to the sub-merchant via destination charge (Stripe) or platform_fees (PayPal).

3. Customer identification (KYC/KYB)

Sub-merchants (artisans): before profile approval, Handsome admin verifies:

• Active Italian VAT number (automatic verification via EU VIES API);
• Owner identity (ID card or passport uploaded at onboarding);
• Tax address / business location;
• For Maker-tier artisans: fiscal data verification completed by admin within 48 business hours;
• Additional onboarding at Stripe Connect and/or PayPal Partner Referrals (full KYC handled by the payment processor).

Customers (buyers): simple identification (verified email, valid payment method). Enhanced identification not required given transaction nature (average ticket < €100, no cash, no anonymous payment).

4. Transaction monitoring

• Cash limit: no cash transactions accepted online. Workshop balance paid by customer to artisan in person remains subject to Italian legal limit (€5,000 per Art. 49 Legislative Decree 231/2007).
• Attention threshold: any single transaction > €1,000 or cumulative series > €5,000 / 30 days from the same customer flagged for manual admin review.
• Automated fraud detection: Stripe Radar (machine learning on 1+ billion transactions) active on every booking. Automatic block of high-risk transactions.
• Velocity check: rate limit applied on booking APIs and artisan accounts.
• Geographic monitoring: transactions from FATF high-risk countries automatically flagged.

5. International sanctions screening

The Platform verifies sub-merchants against the following sanctions lists:

• EU Consolidated Sanctions List;
• UN Security Council Sanctions List;
• OFAC SDN List (US);
• UK HM Treasury Sanctions List.

Screening is performed automatically by Stripe and PayPal at sub-merchant onboarding. Handsome adds ad-hoc additional checks in case of risk flags.

6. Suspicious activity reporting (SAR)

If suspicious money laundering or terrorism financing activity is detected, the Platform promptly reports to the Italian Financial Intelligence Unit (UIF — Bank of Italy) via the Infostat-UIF portal, pursuant to Art. 35 Legislative Decree 231/2007.

7. Record retention

All documentation related to KYC, transactions, communications with customers and artisans, security logs and reports is retained for 10 years from relationship termination, per Art. 31 Legislative Decree 231/2007. Storage in EU database (Supabase eu-central-1) with daily backup and access audit logs.

8. Training and governance

The Owner (Michael Balleroni) is the AML/CTF Compliance Officer and attends annual certified AML/CTF training (ABI Formazione or equivalent, minimum 8 hours/year). This Policy is reviewed annually or upon significant regulatory changes.

9. Approval

This Policy has been approved by the Owner as sole executive officer of the Sole Proprietorship on 19 May 2026.

10. Compliance contact

For any AML/CTF inquiries, reports, or documentation requests:
info@handsomemakers.com