Objective and Standards
The objective is to protect customers and payment networks through a risk-based program that verifies identity, monitors transactions, and reports suspicious activity to competent authorities. The program aligns with EU AML rules, transfer-of-funds information requirements, and applicable sanctions regulations. Internal procedures translate these duties into day-to-day controls for payments, gameplay, and account changes.
Definition of Money Laundering
Money laundering covers converting, transferring, concealing, acquiring, or using property known to be derived from crime, as well as participation or assistance in such acts. It is treated as such even if the underlying conduct occurred in another country.
Governance
An Anti-Money Laundering Compliance Officer (AMLCO) oversees policy, procedures, and escalations, reporting to general management. Material policy changes require management approval and documented implementation steps.
Customer Identification (KYC)
We verify each customer using government-issued photo ID and proof of address. Documents must be clear, readable, and show all corners. Where electronic checks are available, we compare submitted data against independent sources; if checks fail, manual evidence is required.
Three-Step Verification
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Verification is staged to match risk and transaction size. Certain actions are held until the relevant step is completed.
- Step 1: Basic profile data to enable the account and begin low-risk activity.
- Step 2: Photo ID and successful data checks before withdrawals or when cumulative activity reaches stated thresholds.
- Step 3: Source-of-wealth review for higher activity levels or risk triggers.
Source of Funds and Source of Wealth
We may request evidence such as employment income, business ownership, investments, inheritance, or similar lawful sources. If the origin or legitimacy of funds cannot be established, the account may be restricted and authorities notified when required.
Risk Management
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Jurisdictions and customer profiles are grouped into risk tiers. Higher risk leads to earlier verification and enhanced due diligence.
- Low risk: standard three-step flow.
- Medium risk: thresholds are lowered and additional reviews may be applied.
- High risk: access may be refused.
Risk ratings are reviewed and updated as regulatory guidance or exposure changes.
Ongoing Monitoring
Transactions are monitored to identify activity inconsistent with the customer profile, including rapid cycling of deposits and withdrawals or use of unmatched payment instruments. Automated rules flag cases for manual review. Staff must escalate atypical patterns promptly to AMLCO for determination and action.
Sanctions, PEP, and Adverse Media Screening
Customers and relevant counterparties may be screened against sanctions, politically exposed person lists, and negative media. Positive matches lead to enhanced checks or account restrictions.
Prohibited Behaviours
The Service may not be used to mask location, share accounts, use third-party payment methods, or structure activity to avoid verification. Attempts to exploit verification gaps or to move funds between unrelated parties are not permitted.
Record Keeping
Identity and transactional records are retained for at least ten years after the end of the relationship or transaction, stored securely in line with data protection obligations.
Training and Audit
Staff receive mandatory AML training on onboarding and at regular intervals. Internal audit conducts periodic reviews of the program, with findings tracked to resolution.
Reporting of Suspicious Activity
Where a transaction appears unusual, unjustified by the customer profile, or otherwise suspicious, a report is prepared by AML staff and, when required, submitted to the competent Financial Intelligence Unit. Business relationships may be suspended or terminated pending the outcome.
Data Protection
Documentation is handled confidentially and shared only with competent authorities or service providers where permitted by law and necessary for compliance. Security controls cover both online and offline storage.
Contact
For questions about this AML and KYC policy, or to submit compliance documentation following a verification request, email [email protected].