SUBJECT: Young Platform S.p.A.

REGULATORY REFERENCE: Regulation (EU) 2023/1113 (Transfer of Funds Regulation – TFR)

Regulatory Framework

This document attests to the adaptation of Young Platform S.p.A.’s internal procedures to European provisions regarding the transparency of crypto-asset transfers, in compliance with:

• Regulation (EU) 2023/1114 (MiCA): On markets in crypto-assets.
• Regulation (EU) 2023/1113 (TFR): On information accompanying transfers of funds and certain crypto-assets (the so-called “Travel Rule”), which implements into EU law the recommendations of the Financial Action Task Force (FATF) for combating money laundering and terrorist financing.

Scope of Application and Thresholds

In compliance with current legislation and specific provisions for operations within Italian territory:

• Traceability Obligation: The Company is required to collect and transmit identification data of the originator and the beneficiary in crypto-asset transactions.
• Relevance Threshold: For operations falling under Italian jurisdiction, the so-called “Zero Rule” applies, which imposes a data collection obligation for any amount, starting from €0.00.

Operational Compliance Procedures

To ensure full compliance with the obligations set forth in the TFR, Young Platform S.p.A. has implemented the following operational protocols, differentiated based on the nature of the counterparty:

A. Transactions between CASPs (Crypto-Asset Service Providers)

In the case of transfers to or from other crypto-asset service providers (Exchanges, Custodians, etc.):

• The Company acquires and transmits the counterparty’s identification information.
• Data exchange takes place via secure and encrypted protocols that guarantee information integrity and privacy protection.

B. Transactions with Self-Hosted Wallets (Unhosted Wallets)

For transfers involving private addresses not managed by a regulated intermediary:

• Identification: Identification of the private wallet holder is mandatory.
• Ownership Verification: The Company applies risk assessment procedures to the transaction. Where required by risk protocols, the user is required to confirm ownership of the wallet by means of:
  • Formal self-certification;
  • Technical verification procedures (e.g., cryptographic signature or two-factor authentication – 2FA) are integrated into the transaction flow.

Technological Infrastructure (TRUST Protocol)

To fulfil the obligations for secure data transmission between intermediaries (VASPs/CASPs), Young Platform S.p.A. adheres to the TRUST (Travel Rule Universal Solution Technology) solution.

This system enables the compliant exchange of information required by the Travel Rule, ensuring:

1. End-to-end encryption of sensitive user data.
2. Verification of the authenticity of institutional counterparties.
3. Minimisation of cybersecurity risks during the transmission of compliance information.