Anti-Money Laundering Policy

RIGShare LLC ("RIGShare," "we," "us") is committed to preventing the use of its platform for money laundering, terrorist financing, or other illicit financial activity. This Anti-Money Laundering ("AML") Policy outlines the measures we take to detect, prevent, and report suspicious activity in compliance with the Bank Secrecy Act ("BSA"), applicable regulations of the Financial Crimes Enforcement Network ("FinCEN"), and other applicable federal and state laws.

1. Identity Verification

All users must complete identity verification before they can list equipment or make bookings on the RIGShare platform. Our identity verification process includes:

• Government Photo ID: All users must provide a valid government-issued photo identification document (e.g., driver's license, passport, state ID).
• Selfie Verification: Users must complete a live selfie match against their photo ID to confirm their identity.
• Business Verification: Business accounts may be required to provide additional documentation, including business registration documents, EIN verification, and proof of authorized representatives.

Identity verification is processed through our secure third-party provider (Stripe Identity). RIGShare does not store copies of government identification documents on its servers. Accounts that fail identity verification are restricted from transacting on the platform.

2. Transaction Monitoring

RIGShare monitors all transactions on the platform for suspicious patterns and anomalies. Our automated monitoring systems flag activity that may indicate money laundering or other financial crimes, including but not limited to:

• Unusually high transaction volumes in short periods
• Transaction amounts that significantly exceed normal patterns for the equipment type
• Rapid succession of bookings and cancellations
• Circular transaction patterns between related accounts
• Self-dealing: transactions between accounts that share identifying information (e.g., same address, phone number, or custom email domain)
• New accounts engaging in high-value transactions immediately after registration
• Patterns consistent with structuring transactions to avoid reporting thresholds

All transactions are monitored in real time at the point of booking, and our fraud detection systems run daily batch analysis across the platform to identify suspicious trends.

3. Suspicious Activity Reporting

When our monitoring systems or staff identify suspicious activity, RIGShare follows a structured review and reporting process:

• Flagged accounts and transactions are reviewed by our compliance team.
• RIGShare reserves the right to immediately suspend accounts pending investigation when suspicious activity is detected.
• Where required by law, RIGShare will file Suspicious Activity Reports (SARs) with FinCEN.
• RIGShare will not notify the user that a SAR has been filed, in accordance with federal law.

4. Cooperation with Law Enforcement

RIGShare fully cooperates with law enforcement agencies and regulatory bodies in the investigation of suspected money laundering, terrorist financing, fraud, and other financial crimes. We will respond to valid subpoenas, court orders, and lawful requests for information. RIGShare will not tip off users who are the subject of law enforcement inquiries. Our cooperation with law enforcement includes providing transaction records, account information, and other data as legally required.

5. Record Keeping

RIGShare maintains comprehensive records in accordance with the BSA and applicable regulations:

• All transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Identity verification records and results are retained for a minimum of five (5) years after account closure.
• Records of suspicious activity reports and related investigations are retained for a minimum of five (5) years.
• All correspondence related to compliance inquiries is retained for a minimum of five (5) years.

6. Account Suspension and Termination

RIGShare reserves the right to suspend or terminate any account at any time if we suspect the account is being used for money laundering, terrorist financing, fraud, or any other illicit activity. Suspended accounts may have their funds held pending the outcome of an investigation. Users whose accounts are terminated for AML violations are permanently prohibited from creating new accounts on the platform.

7. Employee Training

All RIGShare employees and contractors who handle transactions, customer accounts, or compliance matters receive training on AML regulations, red flag indicators, and internal reporting procedures. Training is provided at onboarding and updated annually.

8. Contact

Questions about this policy or to report suspicious activity? Contact our compliance team at compliance@rigshare.app or write to RIGShare LLC, 17503 La Cantera Pkwy Ste 104 # 25, San Antonio, TX 78257.