This AML/KYC Notice (“Notice”) explains the identity, business-verification, anti-fraud, sanctions and risk-screening measures that may apply when users access PRE-ORDER, create business accounts, make or receive payments for pre-orders, or use other functions creating elevated financial or compliance risk.
PRE-ORDER is an innovative digital platform for fashion pre-orders and related commercial coordination. PRE-ORDER is not a bank, payment institution or escrow agent and does not itself hold customer funds. Stripe is the selected payment provider for B2C transactions. B2B payments, including conditional prepayments, are planned through a separate licensed payment provider once the relevant service is contracted and enabled. Each provider may independently conduct customer due diligence, transaction monitoring, sanctions screening and other legally required controls.
This Notice should be read together with the Terms of Service, Platform Terms, Seller Agreement, Buyer Agreement, Payment & Prepayment Policy, Escrow & Payment Disclosure, Privacy Policy and any verification notice presented during onboarding or a transaction.
Important compliance notice
- Seller/Brand accounts and Business Buyer accounts are the principal account types for which PRE-ORDER expects business identity and ownership verification to be relevant.
- B2C Customers are not necessarily subject to full business or identity verification merely because they browse or place a normal retail pre-order. Additional checks may apply where required by law, Stripe rules, sanctions controls, fraud indicators or transaction risk.
- PRE-ORDER does not represent that it is itself a regulated financial institution or an “obliged entity” under every AML regime. The precise legal duties applicable to PRE-ORDER, Stripe and any B2B payment provider depend on the service, jurisdiction and transaction structure.
- Verification may be performed directly by PRE-ORDER, by Stripe for B2C, by the enabled licensed B2B payment provider, or by specialist verification/compliance providers under appropriate contracts and data-protection safeguards.
- Users must provide truthful, current and complete information and must not use PRE-ORDER to conceal identity, beneficial ownership, location, source of funds, a prohibited transaction or a sanctioned party.
1. Operator, scope and purpose
1.1 The PRE-ORDER Platform is operated by “PRE-ORDER Europe” EOOD, UIC/EIK 208904127, registered at Arthur Residential Complex, Block C, Floor 3, Apartment C44, 8229 Sveti Vlas, Nessebar Municipality, Burgas District, Bulgaria (“PRE-ORDER”, “Operator”, “we”, “us” or “our”).
1.2 PRE-ORDER is intended for Brands and manufacturers, B2B Buyers/retailers and B2C Customers and may be made available in the EU/EEA, Ukraine and other countries where its use is legally and technically available.
1.3 The purposes of verification and screening are to protect users and the Platform, reduce fraud and impersonation, support payment-provider onboarding, enforce Platform rules, comply with applicable sanctions and other legal requirements, and identify transactions or accounts presenting unacceptable compliance risks.
1.4 This Notice describes a risk-based framework. It does not mean that every user is asked for every item of information listed below, or that the same checks apply in every country.
2. Meaning of KYC, KYB and AML
2.1 “KYC” (Know Your Customer) commonly refers to measures used to establish and verify the identity of an individual and assess relevant risk.
2.2 “KYB” (Know Your Business) commonly refers to measures used to establish and verify a business, its registration, activities, representatives, ownership and control.
2.3 “AML” (anti-money laundering) is used in this Notice as a general term for controls intended to prevent or detect misuse of financial and commercial systems for money laundering, terrorist financing, sanctions evasion, fraud or related financial crime. The precise legal obligations depend on the entity and jurisdiction involved.
2.4 “Beneficial owner” or “UBO” means the natural person or persons who ultimately own, control or benefit from a legal entity or arrangement, as determined under the applicable verification standard.
2.5 “PEP” means a politically exposed person. Where relevant, PEP screening may also cover family members and close associates as required by the applicable compliance framework.
3. Who may be verified
3.1 PRE-ORDER may apply different verification levels to user roles and risk profiles. Brand and Business Buyer business profiles must include a company registration number (or legally applicable equivalent) and the authorised representative’s full name and role; additional evidence may be required based on risk and provider requirements.
Sellers / Brands
A Brand or Seller may be required to complete business verification before publishing collections, accepting orders, receiving payouts, buying advertising, accessing selected payment functionality or using higher-risk features.
- company or entrepreneur registration and legal name;
- registered and operating address;
- VAT/tax or company identification numbers where applicable;
- authorised representatives and their authority;
- directors, owners and beneficial owners where relevant;
- bank or payout account information;
- website, business activity and product category;
- supporting corporate or identity documentation where reasonably required.
Business Buyers
A B2B Buyer may be required to complete business verification, particularly for wholesale transactions, staged payments, higher transaction values, invoice-based workflows, restricted jurisdictions or other elevated-risk use cases.
- company name, registration and business address;
- VAT/tax or company ID where applicable;
- authorised purchasing representative;
- beneficial ownership or control information where required;
- billing and payment information;
- business activity and purchase purpose where reasonably necessary.
B2C Customers
Retail Customers will generally be asked only for information needed to create an account, place and deliver an order, process payment, prevent fraud and comply with law. Enhanced identity checks may be requested only where justified by the payment method, transaction risk, sanctions screening, fraud indicators, legal requirement or provider request.
4. Information and documents that may be requested
4.1 Depending on the account type and risk level, verification information may include:
- full legal name, date of birth and nationality where individual identification is necessary;
- email address, telephone number and residential or business address;
- company registration extract, certificate, registry information or equivalent official data;
- VAT, tax, company or other official identifiers;
- identity document and, where necessary, a selfie/liveness or equivalent identity-verification check;
- proof of address;
- authority to act for a company, such as director status, power of attorney or authorised-role confirmation;
- ownership/control structure and beneficial-owner information;
- bank account or payout-account ownership information;
- business model, product categories, expected transaction pattern and countries of operation;
- source-of-funds or source-of-wealth information where enhanced due diligence is justified;
- supporting invoices, order documents, shipping records or transaction explanations where a payment or account activity requires review.
4.2 PRE-ORDER seeks to use proportionate requests. Information should not be requested merely because it is available; the requested data should be relevant to the verification, fraud, sanctions, payment or legal purpose concerned.
5. Verification methods
5.1 Verification may use one or more manual or automated methods, depending on availability and risk.
- comparison of information provided by the user with official or reliable registries;
- document authenticity and consistency checks;
- email, telephone, domain or account confirmation;
- identity-verification technology supplied by a specialist provider;
- bank-account or payment-account ownership checks;
- sanctions, PEP and adverse-risk database screening where legally and proportionately appropriate;
- cross-checking of transaction, device, account and fraud-prevention signals;
- manual review by authorised compliance, risk, finance, operations or support personnel.
5.2 Automated tools may help identify mismatches or risk signals, but a risk signal is not by itself proof of wrongdoing. Where feasible and appropriate, material restrictions should be subject to human review, particularly where the issue cannot be resolved by a simple verification request.
6. Verification by Stripe and other payment providers
6.1 Stripe is the selected provider for B2C payment processing. A separate licensed partner is planned for B2B payment flows, including conditional deposits, subject to contract, geographic eligibility and activation. Depending on the country and implemented service, the relevant provider may require verification of companies, representatives, beneficial owners or other payment participants.
6.2 The relevant payment provider may request information directly, obtain it through PRE-ORDER, or require a provider-hosted verification flow. Its verification decisions, payment and payout restrictions, and legal obligations are governed by its own terms and applicable law.
6.3 PRE-ORDER may share verification data with the applicable payment provider where necessary for onboarding or payment services, subject to the Privacy Policy and applicable data-protection requirements.
6.4 Approval of a PRE-ORDER account does not guarantee acceptance by a payment provider. Provider verification likewise does not prevent PRE-ORDER from applying separate Platform, anti-fraud, product-safety, sanctions or account-integrity controls.
6.5 Where supported and disclosed to the parties, a licensed B2B payment provider may hold a Buyer’s deposit subject to specified production, MOQ, release and refund conditions. The exact arrangement applies only after the provider is enabled and remains subject to its terms and applicable law; PRE-ORDER does not itself custody the funds.
7. Sanctions and restricted jurisdictions
7.1 PRE-ORDER and its payment providers may screen users, beneficial owners, counterparties, payment information and transactions against sanctions or restricted-party information where necessary to comply with applicable law or provider requirements.
7.2 PRE-ORDER must not knowingly facilitate a transaction where doing so would breach an applicable sanctions prohibition, asset-freeze requirement, export/trade restriction or other binding legal restriction.
7.3 The Platform may be unavailable, restricted or subject to additional review in certain countries or territories because of sanctions, payment-network restrictions, local law, security or operational feasibility.
7.4 Users must not use intermediaries, false addresses, alternative accounts, routing techniques or other methods to circumvent a lawful geographic, sanctions or payment restriction.
8. PEP and higher-risk relationships
8.1 Where appropriate to the applicable risk and legal framework, PRE-ORDER or its verification/payment providers may identify whether an individual is a PEP, family member or close associate, or whether another factor creates elevated corruption, sanctions or financial-crime risk.
8.2 A PEP match does not automatically mean that a person has engaged in misconduct. It may require additional verification, senior or specialist review, clarification of the business relationship, source-of-funds/source-of-wealth information, or ongoing monitoring where such measures are applicable.
8.3 PRE-ORDER may decline or restrict a relationship where the residual risk cannot reasonably be managed or where a payment provider refuses or is legally unable to provide the required service.
9. Source of funds and enhanced due diligence
9.1 For higher-risk or unusual transactions, PRE-ORDER or a payment/verification provider may ask for reasonable information about the origin and purpose of funds, the economic rationale of a transaction, the relationship between the parties, or the business purpose of the account.
9.2 Enhanced due diligence may be appropriate where, for example, there are material identity inconsistencies, unusual ownership structures, higher-risk jurisdictions, sanctions/PEP indicators, unusually large or complex transaction patterns, repeated payment disputes, suspected account takeover or other credible risk signals.
9.3 Requests should be proportionate to the identified risk and should not require sensitive personal information that is unrelated to the compliance purpose.
9.4 Failure to provide reasonably requested information may result in delayed onboarding, inability to use payment functionality, payout delay, transaction cancellation, account restriction or termination where permitted by the applicable agreements and law.
10. Transaction monitoring and fraud prevention
10.1 PRE-ORDER may monitor account and transaction activity for patterns indicating fraud, account compromise, sanctions evasion, payment abuse, fictitious pre-order transactions or other misuse. Monitoring may include transaction metadata, payment status, device/session information, account history, order behaviour, shipping information and dispute patterns.
10.2 Monitoring is intended to protect lawful pre-order transactions through the Platform. PRE-ORDER is not a general money-transfer service; users must not create artificial sales, circular payments, sham orders or transactions without a genuine commercial purpose to move funds.
10.3 Examples of activity that may trigger review include repeated failed or disputed payments, mismatched identity and payout information, rapid changes in ownership or bank details, unusual transaction velocity, inconsistent shipping information, suspicious linked accounts, or attempts to split transactions to avoid controls.
10.4 PRE-ORDER may use automated rules to prioritise cases for review. Where a significant account action is based on a risk flag, authorised personnel may review the available information before or after applying a proportionate protective restriction, depending on urgency.
11. User obligations and prohibited conduct
11.1 Users must cooperate with lawful and proportionate verification requests and ensure that information provided to PRE-ORDER or the applicable payment provider is accurate, complete and current.
- do not impersonate another person or business;
- do not submit forged, altered, stolen or misleading documents;
- do not conceal the true beneficial owner or controlling person;
- do not use nominee arrangements, shell structures or intermediaries to evade verification or sanctions controls;
- do not use payment methods or payout accounts without proper authorisation;
- do not create fictitious orders or use the Platform primarily to transfer money rather than purchase genuine Products offered through PRE-ORDER;
- do not structure or split transactions to evade verification, risk limits or legal reporting thresholds;
- notify PRE-ORDER where material verification information changes, including business status, authorised representatives, beneficial ownership or payout information.
12. Ongoing verification and information updates
12.1 Verification may be repeated. PRE-ORDER or the relevant payment provider may request updated information when documents expire, company details or ownership change, payment activity changes materially, a new regulated function becomes available, risk indicators arise or periodic review is required by provider rules or law.
12.2 Users should update their profile promptly when material business or contact information changes. PRE-ORDER may temporarily limit affected functions until a material discrepancy is resolved.
12.3 A previously verified status does not create a permanent entitlement to unrestricted access where new legal, fraud, sanctions, product-safety or payment risks arise.
13. Account restrictions, payment holds and refusal of service
13.1 PRE-ORDER may, where reasonably necessary and permitted by law and contract, delay onboarding, request additional evidence, restrict selected functions, pause transaction processing, prevent new orders, limit payouts, suspend an account or terminate access when a material compliance risk cannot otherwise be managed.
13.2 Stripe or another enabled payment provider may independently restrict payment acceptance, conditional holding, transfers or payouts under its own terms. A provider restriction may make individual PRE-ORDER functions unavailable even without a separate platform suspension.
13.3 Restrictions should be proportionate to the risk and may be lifted when required information is supplied or the issue is resolved. In urgent fraud, security, sanctions or legal situations, PRE-ORDER may act before contacting the user.
13.4 PRE-ORDER may be unable to disclose specific reasons, risk rules, sanctions-screening details, reports, law-enforcement requests or provider instructions where disclosure is prohibited, would compromise security, or would undermine an investigation or compliance control.
14. Suspicious activity, authorities and cooperation
14.1 Where PRE-ORDER, an enabled payment provider or another relevant participant is legally required or permitted to report, preserve, block, freeze, reject or disclose information regarding suspected unlawful activity, it may do so under the applicable legal framework.
14.2 PRE-ORDER may respond to valid requests from competent authorities and may preserve relevant records where required by law, legal process, fraud investigation, dispute management or contractual recordkeeping obligations.
14.3 This Notice does not state that PRE-ORDER has the same statutory reporting duties as a bank or regulated payment institution. Payment providers and other regulated participants may have separate and more extensive AML reporting obligations.
14.4 PRE-ORDER will not notify a user about a report, investigation or restricted disclosure where doing so would be unlawful or would undermine a legitimate compliance or security purpose.
15. Data protection and confidentiality
15.1 Verification information may contain sensitive identity, corporate, ownership, financial and risk-related data. PRE-ORDER will process such information for defined verification, payment, fraud, security and compliance purposes in accordance with its Privacy Policy and applicable data-protection law.
15.2 Access should be limited to authorised personnel and service providers with a need to know. Appropriate technical and organisational safeguards should include role-based access, secure transmission/storage, logging and retention controls proportionate to the information involved.
15.3 Identity documents, payment credentials and verification records are not intended to be used as features for PRE-ORDER demand-forecasting AI. Where analytical or AI datasets are used, directly identifying data should be separated, minimised, pseudonymised or aggregated where appropriate.
15.4 Data may be shared with Stripe, the licensed B2B payment provider once selected and enabled, identity/KYB verification providers, fraud-prevention vendors, professional advisers, hosting/security providers, competent authorities or others where necessary and lawful. International transfers will use applicable safeguards where required.
15.5 Retention periods depend on the purpose, applicable legal obligations, payment-provider requirements, contractual limitation periods, fraud/security needs and dispute or audit requirements. Data will be deleted or anonymised when no longer required, unless continued retention is legally justified.
16. Automated screening and human review
16.1 PRE-ORDER may use automated signals, matching tools or provider-generated risk results to identify cases requiring attention. Such tools can produce false positives and should not be treated as conclusive evidence of wrongdoing without appropriate context.
16.2 Where legally required or reasonably practicable, users may be asked to provide clarification or additional evidence when a material decision is based on an unresolved verification mismatch or risk flag.
16.3 PRE-ORDER’s demand-forecasting AI is separate from AML/KYC verification. Production recommendations are designed as decision support for Brands and are not intended to make autonomous financial-crime or legal-status determinations about individuals.
17. Rights, corrections and challenges
17.1 Users should contact PRE-ORDER if verification information held by the Platform is inaccurate or out of date. PRE-ORDER may require reasonable proof before changing verified identity or ownership information.
17.2 Data subjects may exercise applicable rights under data-protection law, subject to lawful limitations that may apply to AML, fraud-prevention, legal-claims or regulatory records. Details are provided in the Privacy Policy and GDPR Notice.
17.3 If access is restricted due to a verification issue, a user may contact support to provide clarification or request review, unless PRE-ORDER is legally prohibited from discussing the relevant issue.
17.4 A payment-provider decision may have to be challenged under that provider’s own procedure. PRE-ORDER cannot override a lawful independent risk or compliance decision taken by Stripe, the B2B payment provider, a bank, card issuer or other regulated participant.
18. Changes to this Notice
18.1 PRE-ORDER may update this Notice to reflect changes in payment infrastructure, verification providers, Platform functionality, legal requirements, sanctions rules or risk controls.
18.2 Material changes will be communicated or made available through the Platform or website as appropriate. The effective date shown at the top identifies the applicable published text.
18.3 This Notice is informational and forms part of the wider PRE-ORDER compliance framework. In case of conflict, mandatory law and the specific binding agreement applicable to the transaction take precedence.
19. Contact
Questions concerning this Notice, verification requests or compliance-related access restrictions may be sent to: info@b2b-agency.cc.
Operator: “PRE-ORDER Europe” EOOD, UIC/EIK 208904127, Arthur Residential Complex, Block C, Floor 3, Apartment C44, 8229 Sveti Vlas, Nessebar Municipality, Burgas District, Bulgaria.