Compliance
& AML.

01 / Our Position

Dram X is a marketplace operator and disclosed commercial agent. We are not a bank, an electronic money institution, or an FCA-authorised investment firm. The whisky casks and bottlings listed on the platform are physical goods and are not regulated financial instruments. Regulated payment and cryptoasset activities are performed by our partners under their own licences and registrations.

02 / AML Framework

Dram X operates an anti-money-laundering (AML) and counter-terrorist-financing (CTF) framework aligned with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) and HMRC and FCA guidance applicable to high-value dealers, marketplaces, and cryptoasset-adjacent businesses. The framework includes a written firm-wide AML risk assessment, customer and vendor due diligence, ongoing transaction monitoring, sanctions screening, and recordkeeping for five years from the end of the business relationship.

03 / Money Laundering Reporting Officer (MLRO)

Dram X has appointed a Money Laundering Reporting Officer responsible for the AML programme, suspicious-activity reporting to the National Crime Agency, and engagement with regulators. The MLRO and Nominated Officer is [MLRO name TBC]; written enquiries from regulators or law-enforcement agencies should be addressed to mlro@dramxwhisky.com.

04 / Customer Due Diligence (KYC)

Customer identity is verified at the point a transaction or cumulative spend meets the thresholds set out in our KYC strategy. Verification is operated through Sumsub (Sum and Substance Ltd.) and includes document, biometric, and sanctions/PEP screening. Adverse-result accounts are subject to enhanced due diligence and may be declined or restricted.

05 / Vendor Due Diligence (KYB)

Vendors are subject to Know-Your-Business verification before any listing goes live or any payout is made. KYB covers entity verification, ultimate-beneficial-ownership identification, director identification, sanctions and adverse-media screening, and evidence of relevant alcohol-licensing and VAT registration. KYB is operated through Sumsub. Stripe Connect runs a parallel onboarding for its own regulatory obligations as the card payment processor.

06 / Cryptoasset Receipts — Outsourced to BCB Group

Dram X does not custody cryptoassets and does not perform cryptoasset-to-fiat conversion as a business activity. Cryptoasset payments are received and converted by BCB Group Limited, which is registered with the Financial Conduct Authority under MLR 2017 as a cryptoasset firm. The fiat that arrives at Dram X is GBP. This structure removes the requirement for Dram X to hold its own FCA cryptoasset firm registration; the position is kept under review and will be re-assessed if our activity profile changes.

07 / Wallet Screening

Incoming cryptoasset payments are screened against sanctions lists and illicit-finance indicators (mixers, ransomware-linked clusters, darknet markets, sanctioned addresses). Payments returning an adverse screening result are declined or held for compliance review; outcomes are recorded in the transaction record.

08 / Sanctions

Dram X screens customers, vendors, and counterparties against UK, EU, UN, and OFAC sanctions lists at onboarding and on an ongoing basis. We do not knowingly transact with, or facilitate transactions for, persons or jurisdictions subject to comprehensive sanctions. List matches trigger an immediate hold pending compliance review.

09 / Reporting Obligations

Dram X reports suspicious activity to the National Crime Agency (UKFIU) as required by the Proceeds of Crime Act 2002 and the Terrorism Act 2000. Where transactions or customers fall within the High Value Dealer regime, Dram X will register with HMRC and operate accordingly. Where a regulator or law-enforcement agency lawfully requests information, Dram X cooperates within the bounds of the request.

10 / Regulated Partner Disclosures

• Card payments: Stripe Payments UK Ltd., authorised by the FCA as an Electronic Money Institution.
• Vendor card payouts: Stripe Connect — operated by Stripe Payments UK Ltd.
• Cryptoasset receipts and conversion: BCB Group Limited, registered with the FCA under MLR 2017 as a cryptoasset firm.
• Operating banking and vendor GBP payouts: Revolut Ltd. (Revolut Business), authorised under UK banking and EMI regimes.
• Identity verification (KYC/KYB) and ongoing screening: Sum and Substance Ltd. (Sumsub).

11 / Tax & Duty

Vendors are responsible for excise duty, VAT, and other taxes applicable to the goods they sell. Dram X facilitates self-billed VAT invoicing in vendors' names under HMRC Notice 700/62. Where the High Value Dealer regime applies to Dram X's own activities, Dram X will register with HMRC.

12 / Geographic Scope

Dram X sells to customers in the United Kingdom and selected additional jurisdictions disclosed at checkout. We do not sell to, or accept payment from, persons in jurisdictions subject to comprehensive sanctions, or in any jurisdiction we determine to present unacceptable legal or compliance risk. Where local law restricts importation, possession, or consumption of alcoholic spirits, the responsibility for compliance with that law rests with the buyer.

13 / Contact

Compliance and regulator enquiries: mlro@dramxwhisky.com. Data protection enquiries: see Privacy Policy. General queries: sales@dramxwhisky.com. Registered office: DX Wealth Ltd., 5 South Charlotte Street, EH2 4AN Scotland, United Kingdom.