ENDNGO
AML AND COMPLIANCE STATEMENT
MARKOEU OÜ | | Effective: 06 April 2026
1. Purpose
MARKOEU OÜ (“Company”, “endngo”) is committed to preventing fraud, misuse of its services, and violations of applicable financial and sanctions laws.
The Company operates an e-commerce platform for digital products (Game Keys) and does not provide regulated financial services. Accordingly, the Company applies a risk-based and proportionate approach to compliance.
The Company is not generally subject to full customer due diligence obligations under Money Laundering and Terrorist Financing Prevention Act (“MLTFPA”). However, it implements reasonable safeguards to mitigate risks associated with fraud, payment abuse, and sanctions violations.
2. Risk-Based Compliance Model
The Company applies internal controls designed to identify and mitigate:
- payment fraud and unauthorised transactions
- misuse of digital goods
- transactions involving sanctioned persons or jurisdictions
- abusive purchasing patterns (e.g. bulk buying for resale)
These controls are proportionate to the nature of the Company’s business and are applied selectively based on risk indicators.
3. Identity Verification (KYC)
The Company does not routinely require identity verification from Users.
However, the Company reserves the right to request identity verification or additional information where reasonably necessary, including in cases such as:
- high-value or unusual transactions
- suspected fraud or abuse
- repeated refund or chargeback activity
- payment provider requirements
- legal or regulatory obligations
Any such verification is carried out on a case-by-case basis and limited to what is necessary.
The Company applies the principle of data minimisation and does not intentionally collect excessive personal data.
4. Sanctions Compliance
The Company does not permit the use of its services by individuals or entities subject to applicable international sanctions regimes, including:
- European Union sanctions
- United Nations sanctions
- United States (OFAC) sanctions
- United Kingdom (OFSI) sanctions
The Company may implement automated or manual checks to identify and prevent transactions involving sanctioned parties.
Where a potential match is identified, the Company may suspend or refuse the transaction pending review.
5. Transaction Monitoring and Fraud Prevention
The Company uses automated and manual systems to detect suspicious or high-risk activity.
In practice, most transactions are processed without additional review. However, a limited number of transactions may be flagged for further checks.
Where necessary, the Company may:
- delay or cancel transactions
- request additional information
- restrict or suspend accounts
Decisions are made based on reasonable assessment of risk.
6. Payment Controls
Payments are processed through regulated third-party payment service providers.
The Company relies in part on these providers for fraud detection, authentication, and compliance checks.
The Company does not store full payment card details and does not directly process payment credentials.
7. Cooperation with Authorities
The Company co-operates fully with the Estonian Financial Intelligence Unit, tax authorities, law enforcement bodies, and judicial authorities. The Company fulfills all mandatory disclosure obligations under applicable law and does not notify customers of reporting actions where such notification is prohibited by the tipping-off provisions of the MLTFPA.
8. Record Keeping
The Company retains relevant transaction and compliance-related records for a minimum period of five (5) years from the end of the business relationship or the date of the relevant transaction, in accordance with MLTFPA § 47. All records are maintained securely and are accessible only to authorised personnel and to competent authorities pursuant to lawful requests.
9. Proportionality and User Rights
The Company applies its compliance measures in a proportionate manner.
In practice:
- most Users are not subject to identity verification
- most transactions are completed without interruption
Where actions are taken (e.g. suspension or verification), Users may contact the Company for clarification and review.
13. Contact Us
Company: MARKOEU OÜ
Address: Harju maakond, Tallinn, Pirita linnaosa, Lodjapuu tee 101, 12113, Estonia
Compliance Contact: [email protected]
Effective Date: 06 April 2026