Monitoring and Compliance Procedures

2.1 Automated AML Flags

All transactions are subject to automated monitoring. The following rules trigger a flag for manual review:

• Single transaction exceeding 5,000 tokens from a seller with fewer than 10 completed sales
• Account less than 30 days old completing more than 10 sales in a 7-day period
• Same buyer and seller completing 3 or more transactions within 24 hours, each below 5,000 tokens (structuring indicator)
• Buyer and seller sharing the same IP address or device ID (self-dealing indicator)
• Seller receiving 2 or more chargebacks within a 30-day period

Flagged transactions are reviewed by the Nominated Officer within 24 hours and recorded in the platform moderation audit log.

2.2 Sanctions Screening

All users are screened against the Open Sanctions database (opensanctions.org) at two points:

• On registration: full name and country checked against UK, UN, and OFAC sanctions lists
• On each transaction: buyer and seller re-checked before payment is processed

A match results in automatic account suspension and immediate escalation to the Nominated Officer. Sanctions lists are re-screened monthly across all active accounts. Matches are reported via SAR Online to the NCA where required.

2.3 Chargeback Monitoring

Chargeback rates are monitored monthly via the payment processor's merchant portal. The target chargeback rate is below 0.5% of monthly transactions. Where the rate approaches 0.5%, the Nominated Officer investigates and takes corrective action including seller suspension or enhanced listing scrutiny.

3.1 Pre-Publication Screening

All listings and media are screened before publication using the following automated controls:

• IWF Image Intercept: every image and video upload is hashed and checked against the IWF illegal image database. Known CSAM is blocked automatically before publication and reported to IWF and NCMEC within 1 hour.
• AI content analysis via Hive: all uploaded media is analysed to detect prohibited visual content, including but not limited to background or incidental people, prohibited substances, alcohol, animals, weapons, blood, and minors.
• Facial recognition verifies that the identity of persons depicted matches verified Creator records.
• Keyword filter: listing titles, descriptions, tags, usernames, and messages are checked against a prohibited keyword list. Matches result in the content being held for manual review.
• Pattern detection identifies attempts to circumvent platform rules, including off-platform solicitation.
• New seller listings: all listings from newly verified Creators are held for mandatory manual review by the Nominated Officer for an initial period before publication, regardless of automated screening results.

Listings are only published after passing all automated checks or after manual review clears a held listing.

3.2 Manual Review SLAs

The Nominated Officer reviews held listings within the following timeframes:

• Critical (CSAM, NCII, trafficking): within 1 hour
• High (prohibited item, suspicious provenance, new-seller submission): within 24 hours
• Standard (keyword flag, general review): within 72 hours

4.2 Seller Verification

All sellers pass through a mandatory two-layer verification process:

• Layer 1: Yoti document verification. Government-issued photo ID plus selfie liveness check. Age 18+ confirmed. Pass/fail result only is stored by Sliqd.
• Layer 2: Manual social media authenticity check by the Nominated Officer. The seller posts a video or message on their linked social media account referencing their Sliqd username and sends the link to Sliqd for review. The Nominated Officer verifies the account matches the verified identity before activating the seller.

No seller is activated without passing both layers.