Anti-Money Laundering (AML) Policy – Light Version

Last updated: September 10, 2025

Company: Livappy OÜ
Jurisdiction: Estonia, EU
Effective Date: September 10, 2025

1. Purpose

The purpose of this AML Policy is to outline Livappy OÜ's approach to preventing money laundering and terrorist financing in connection with its activities as a digital marketplace for real estate listings, memberships, and advertising.

Important Note: Livappy OÜ is not a financial institution and does not directly process payments for property transactions or rentals. The company only receives payments related to advertising services and membership subscriptions.

2. Scope

This Policy applies to:

  • All employees, contractors, and partners of Livappy OÜ.
  • All activities related to payments for Livappy memberships and advertising services.
  • All third-party integrations for payment processing (Stripe) and identity verification (Veriff).

3. Regulatory Background

EU Framework: Livappy OÜ operates under EU AML Directives (currently the 6th AML Directive, 2018/1673/EU).

National Supervision: Rahapesu andmebüroo (RAB) in Estonia.

Classification: Livappy OÜ is not a "financial institution" or "obliged entity" under Estonian AML law for its current business model. AML responsibilities primarily remain with real estate agents, agencies, and other obliged entities conducting property transactions.

4. Risk Approach

Given Livappy's business model:

  • AML risks are low.
  • Funds received by Livappy are limited to advertising and membership fees.
  • Escrow payments for rentals or property transactions are not currently part of the business model.

This low-risk profile allows for a proportionate and simplified approach to AML compliance.

5. Third-Party Providers

Livappy OÜ relies on the following regulated service providers:

Stripe Payments Europe Ltd.

For payment processing (regulated financial institution with full AML compliance).

Veriff OÜ

For optional digital identity verification of real estate agents and advertisers (to improve trust and platform integrity).

Both providers maintain their own comprehensive AML compliance programs in accordance with EU and Estonian regulations.

6. Responsibilities

Livappy OÜ ensures:

  • Payments are processed only through AML-compliant providers.
  • Platform integrity through optional identity verification services.
  • Cooperation with relevant authorities when required.

Real estate agents and agencies:

Remain responsible for fulfilling AML/KYC obligations connected to property sales, rentals, and client transactions.

Compliance Officer: For the purpose of this Policy, the director of Livappy OÜ acts as the designated person responsible for AML compliance.

7. Suspicious Activity

Although Livappy does not handle client funds directly, the company:

  • Reserves the right to suspend or terminate accounts in case of suspicious activity (fraud, sanctions, fake listings).
  • Will cooperate with law enforcement or FIU Estonia (RAB) if notified of potential AML risks.

Reporting: Any suspicious activities identified will be reported to the appropriate authorities in accordance with Estonian law and EU directives.

8. Future Developments

Planned Enhancements

Livappy OÜ intends to introduce escrow and rental deposit services in the future. At that stage, Livappy OÜ will update and expand this AML Policy to ensure full compliance with Estonian and EU AML regulations, including:

  • Mandatory KYC for landlords, tenants, and agents
  • Enhanced due diligence procedures
  • Transaction monitoring systems
  • Comprehensive record-keeping requirements
  • Regular risk assessments

9. Review

This Policy will be reviewed annually or upon major changes in Livappy's business model.

Regular reviews ensure the policy remains current with:

  • Changes in EU and Estonian AML regulations
  • Evolution of Livappy's business model
  • Emerging money laundering risks in the real estate sector
  • Guidance from supervisory authorities

Contact Information

For questions regarding this AML Policy, please contact:

Email: info@livappy.com

Company: Livappy OÜ (registrikood 17298558)

Address: Harju maakond, Tallinn, Kesklinna linnaosa, Sakala tn 7-2, 10141, Estonia

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