AML / KYC POLICY
1. General Statement
This Anti-Money Laundering and Know-Your-Customer Policy (“Policy”) describes the compliance procedures applied by ELEMENTS ENERGY SOCIEDAD LIMITADA (the “Issuer”) in connection with the RockRail STO digital security offering. The Issuer maintains a risk-based framework designed to comply with Spanish and EU AML/CTF obligations, including Ley 10/2010, EU AML Directives, and relevant FATF guidance. All participants must complete identity verification and suitability checks before being admitted to the offering.
2.Identification & Verification Procedures
To prevent misuse of the platform, every individual or entity engaging with the RockRail STO must undergo a full verification process. The Issuer collects basic identity details, verifies government-issued identification documents, confirms the residential or registered address, and applies sanctions, PEP, and adverse-media screening. Proof of Address may be requested where necessary, and a liveness or video check may be required to authenticate the identity presented.
Legal entities must provide documentation confirming incorporation, the identity of directors or authorised representatives, and information about ultimate beneficial owners. Additional evidence may be required when the ownership structure is complex or when risk indicators are present.
The Issuer may request further information—including Source of Funds or Source of Wealth declarations—whenever additional clarity is needed to complete the compliance review.
3.Enhanced Review
Participants assessed as presenting a higher degree of risk may be subject to enhanced due diligence. This may include additional documentation, clarifying interviews, more frequent monitoring, periodic reverification, or any supplementary measure deemed necessary under applicable regulations. The Issuer may decline participation where verification cannot be satisfactorily completed.
4.Investor Understanding & Suitability Assessment
In addition to standard KYC measures, the Issuer conducts an Investor Understanding Questionnaire. This assessment confirms that the prospective participant has a general awareness of the nature of digital assets, the characteristics of tokenized instruments, the risks of price volatility and limited liquidity, and the fundamentals of the rare-minerals sector that underpins the STO.
The questionnaire is not an advisory tool and does not evaluate investment merit; its purpose is solely to confirm that participants possess a minimum level of understanding of the type of instrument they are engaging with. The Issuer may restrict access if responses indicate insufficient comprehension or misalignment with the offering’s profile.
5.Ongoing Monitoring
Following initial verification, the Issuer conducts ongoing monitoring of user activity, including periodic review of documentation, continued sanctions and watchlist screening, and assessment of any behaviour that may suggest elevated risk. Transactions or actions that appear unusual, inconsistent, or unexplained may be subject to additional review. Where required by law, relevant information may be submitted to competent authorities.
6.Data Handling & Recordkeeping
All information obtained during the AML/KYC process is retained for the minimum period required under Spanish and EU regulations. Data is stored securely and processed in accordance with GDPR and internal data-protection protocols. Access to such data is restricted to authorized personnel and may be shared only with regulatory or supervisory bodies when legally required.
7.Eligibility & Jurisdictional Restrictions
Participation in the STO may be restricted or denied to individuals or entities located in jurisdictions subject to international sanctions, identified as high-risk by the EU or FATF, or where digital-asset securities cannot legally be offered. The Issuer may modify eligibility criteria at any time to reflect regulatory developments or internal compliance requirements.
8.Policy Updates
The Issuer may revise this Policy without prior notice to ensure continued alignment with evolving regulatory frameworks and operational practices. Continued use of the platform constitutes acknowledgement of the updated Policy.
9.Contact
Questions relating to verification or compliance may be directed to:
ELEMENTS ENERGY SOCIEDAD LIMITADA
529900TSJXZGZRTBU403
Paseo de la Alameda 45, 46010
Valencia, Spain
www.rockrail-sto.com
contact@rockrail-sto.com