Compliance Memorandum

Executive summary

Konatamo LLC operates satooB, a closed-loop loyalty SaaS platform serving B2B merchants. Konatamo's Operating Agreement (Article IX) explicitly classifies the company as a "Pure Loyalty SaaS" and prohibits all activities that would qualify it as a Money Services Business (MSB), Virtual Asset Service Provider (VASP), money transmitter, or payment processor under U.S. federal or state law.

This memo addresses recurring questions from financial-compliance and Trust & Safety teams regarding our brand identity (use of the Bitcoin symbol "₿" in our logo and mascot) and clarifies why our brand iconography does not affect our regulatory classification.

1. Corporate structure

• Legal entity : Konatamo LLC (DBA satooB LLC)
• Type : Single-Member, Member-Managed Limited Liability Company
• State of formation : New Mexico, USA
• Date of formation : March 28, 2026
• Entity ID (NM SOS) : 0008091949
• Filing number : 3179847
• Federal EIN : 35-2955786
• Member : foreign individual (French national, EU resident)
• Tax classification : disregarded entity (foreign-owned, subject to Form 5472 and Form 1120-equivalent reporting under IRC §6038A)
• FinCEN Beneficial Ownership Information : filed in compliance with the Corporate Transparency Act (31 USC §5336)

2. Primary business (per OA Article 9.1)

The Operating Agreement states :

"satooB is a software-as-a-service platform that enables business-to-business merchant clients to administer customer loyalty programs for their consumer end-customers. Through the platform, Merchants reward their consumer end-customers with internal accounting units (satoPOINTS) that consumers may redeem solely for fiat-denominated discount vouchers honored by participating Merchants."

Article 9.1 establishes that Konatamo LLC's only commercial activity is providing software infrastructure to merchant clients. Konatamo LLC does not transact directly with consumer end-users.

3. Pure Loyalty SaaS Classification (per OA Article 9.2)

The Operating Agreement explicitly classifies Konatamo LLC as a Pure Loyalty SaaS. The Service is positioned as :

• a software service that mediates loyalty interactions between Merchants and their consumer end-customers ;
• and is not, at any time :
  • a money transmitter, money services business, or payment institution under the laws of any jurisdiction ;
  • a deposit-taking institution, electronic-money institution, or stored-value issuer ;
  • a virtual asset service provider, cryptocurrency exchange, broker, dealer, custodian, or wallet provider ;
  • a securities issuer, broker-dealer, or investment adviser ;
  • a fiduciary of any End-User.

4. Prohibited activities (per OA Article 9.3)

The following activities are explicitly prohibited by the Operating Agreement and are reproduced in our public Acceptable Use Policy verbatim :

• (a) Operation of a digital asset exchange, a cryptocurrency exchange, or any other platform for the purchase, sale, swap, or trading of cryptocurrencies, virtual currencies, stablecoins, security tokens, utility tokens, non-fungible tokens, or other digital assets.
• (b) Provision of custodial wallet services, hosted wallet services, or any service involving the custody, holding, or transmission of cryptocurrencies, virtual currencies, digital assets, or other digital tokens for or on behalf of any person.
• (c) Issuance, sale, distribution, or marketing of cryptocurrencies, virtual currencies, security tokens, utility tokens, non-fungible tokens, or any other instrument that may be characterised as a security under U.S. federal or state securities laws.
• (d) Operation of a money services business, money transmitter, payment processor, or any other money transmission activity that would require licensure under U.S. federal law (including the Bank Secrecy Act) or under any U.S. state money transmission law.
• (e) Conversion, redemption, or exchange of points or rewards into United States dollars or any other fiat currency, into any cryptocurrency or digital asset, or into any other monetary or quasi-monetary instrument.
• (f) Holding, custody, or transmission of fiduciary funds for or on behalf of consumer end-users, or maintenance of any account holding consumer end-user funds.
• (g) Sale of cryptocurrency or any digital asset to consumer end-users, or to any other person, in any form whatsoever.
• (h) Any activity that is unlawful under the laws of the State of New Mexico, the United States of America, or any jurisdiction in which the Customer conducts business.

5. Nature of satoPOINTS (per OA Article 9.4)

The Operating Agreement provides :

"satoPOINTS are internal accounting units used solely to track participation in Merchant-administered loyalty programs. satoPOINTS :

• have no monetary value ;
• are not legal tender ;
• are not redeemable for cash or for any fiat currency ;
• are not redeemable for any cryptocurrency or digital asset ;
• are not transferable between consumer end-users for value ;
• may be redeemed by you solely for fiat-denominated discount vouchers issued by, and honoured at, participating Merchants ;
• do not constitute a security, a deposit, a stored-value instrument, electronic money, or money transmission under any applicable law."

This characterisation is reproduced verbatim in our public User Terms Section 4.

6. No direct consumer fiduciary relationship (per OA Article 9.5)

The Operating Agreement makes clear that Konatamo LLC has no fiduciary relationship with any consumer end-user. Konatamo LLC :

• holds no consumer end-user funds, deposits, fiduciary assets, custodial balances, or stored-value balances ;
• maintains no account in the name of any consumer end-user with monetary or fiduciary character ;
• owes no debt, obligation to pay, or money-equivalent obligation to any consumer end-user.

The award of satoPOINTS to a consumer end-user is a marketing benefit granted by the Merchant administering the loyalty program, not a financial obligation of Konatamo LLC.

7. Regulatory positioning — U.S. federal

Konatamo LLC does not engage in money transmission as defined by 31 USC § 5330 or by FinCEN guidance (FIN-2013-G001 and subsequent guidance). Our activities fall outside the scope of the Bank Secrecy Act money-services-business framework because :

• we do not transmit funds between persons ;
• we do not exchange currency, virtual currency, or digital assets ;
• we do not hold customer funds ;
• our internal accounting units (satoPOINTS) are non-transferable, non-convertible, and have no monetary value.

8. Regulatory positioning — U.S. state

Konatamo LLC is not subject to state money-transmission-license (MTL) requirements because we do not engage in money transmission as defined by the Uniform Money Services Act (UMSA) or any state-specific MTL statute. Our model is a closed-loop loyalty program with discount-voucher redemption, exempted under most states' merchant-issued-instrument exemptions (see e.g. NMSA 1978 §58-32-104, equivalent provisions in Texas Finance Code §151.302, California Money Transmission Act §2010, Illinois 205 ILCS 657/15, and equivalents in other states).

9. Regulatory positioning — European Union

10. Brand identity and iconography

The satooB logo features a stylised "B" character that visually evokes the Bitcoin symbol "₿". The satoo mascot incorporates similar iconography. These design choices are aesthetic — they reinforce our positioning as a modern, digital-native, gaming-inspired loyalty platform. They do not modify our regulatory classification, our business model, or the nature of satoPOINTS.

The use of the ₿ symbol in branding is widespread across non-crypto industries, including fashion (Bitcoin-themed apparel), gaming (in-game economies), and fintech (point-of-sale terminals). It functions as a visual signifier of "digital value" or "modern reward" rather than as an indication of cryptocurrency activity.

This memorandum is provided to clarify that our brand iconography does not contradict our Operating Agreement classification or our prohibited-activities list. A public-facing FAQ on this topic is available at /faq#about-our-brand.

11. Corporate treasury activities

Konatamo LLC may, from time to time, hold digital assets on its corporate balance sheet for the limited purpose of financial hedging against the company's obligations to settle merchant voucher redemptions. This is corporate treasury / hedging activity :

• conducted entirely on Konatamo's own balance sheet ;
• not on behalf of consumer end-users (per OA Article 9.5) ;
• not advertised, offered, or sold to any party ;
• not constituting custodial services for any third party.

This activity is permissible under U.S. federal and state law as ordinary corporate treasury management and does not subject Konatamo LLC to MSB / VASP / MTL classification.

12. Data protection

Konatamo LLC complies with the GDPR (EU residents), the UK GDPR, the CCPA / CPRA (California residents), the LGPD (Brazil), Quebec's Loi 25, the PIPEDA (Canada federal), and other applicable data-protection regimes. Our complete data-protection disclosures are documented in our Privacy Policy and our Data Processing Agreement. Data-subject rights and processing-related inquiries are handled by our Data Protection Officer at privacy@satoob.com.

13. Contact for compliance inquiries

• Konatamo LLC, 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110, USA
• Phone : +1 (505) 267-7724
• Legal email : legal@konatamo.com
• Compliance email : compliance@konatamo.com

We commit to responding to legitimate compliance inquiries from financial institutions, payment processors, and regulators within five (5) business days.

Konatamo LLC, by its authorised representative

Signature on file (electronic acknowledgement)