AML Policy

GAME TRADE, UAB

Company code 304750778

Juozo Balčikonio str. 9, LT-08247, Vilnius, Lithuania

ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING POLICY

July 31st, 2019

COMPANY POLICY

  1. UAB “Game Trade” (hereinafter the Company) operates online shop “FortniteItems.gg” and is committed to conduct business operations in a transparent and open manner consistent with its regulatory obligations.

  2. The Company takes a zero-tolerance approach to money laundering, terrorist financing activity and other financial crimes, therefore it establishes the anti-money laundering and counter-terrorism financing policy (hereinafter the Policy) in order to set the principles and define anti-money laundering and counter-terrorism financing (hereinafter AML/CTF) framework of the Company.

  3. The Company ensures it has internal procedures in place to complement this Policy and monitoring of adherence to those procedures also takes place.

  4. All staff is continuously trained in AML/CTF processes and procedures for the Company and actively participates in preventing the services of the Company from being exploited by criminals and terrorists for money laundering or terrorist financing purposes.

  5. The objectives of this Policy are:

  • ensuring the Company’s compliance with applicable laws and regulations;

  • protecting the Company and its staff as individuals from the risks associated with breaches of the laws and regulations;

  • preserving the good name of the Company against the risk of reputational damage presented by implication in money laundering and terrorist financing activities;

  • making a positive contribution to the fight against crime and terrorism.

  1. To achieve these objectives, it is the policy of this Company that:

  • every member of staff shall meet their personal obligations as appropriate to their role and position in the Company;

  • neither commercial considerations nor a sense of loyalty to customers shall be permitted to take precedence over the Company’s AML/CTF commitment;

  • CEO of the Company shall be responsible for running the Company in accordance to this Policy;

  • this Policy shall outline the positive actions to be taken by staff during their work, and the CEO shall keep these under review to ensure their continuing appropriateness.

MONEY LAUNDERING, TERRORIST FINANCING AND RELATED RISKS

  1. Money laundering is the process of disguising the origin of the proceeds of crime. Terrorist financing provides funds for terrorist activity. The use of products and services by money launderers and terrorists exposes the Company to significant criminal, regulatory and reputational risk.

  2. Primarily, the Company and its staff must avoid any business activity that might be related to money laundering:

  • knowingly assisting in concealing, or entering into arrangements for the acquisition, use, and/or possession of, criminal property;

  • failing to identify and/or report knowledge, suspicion, or where there are reasonable grounds for knowing or suspecting, that another person is engaged in money laundering or terrorist financing.

  1. Additionally, the Company is aware that there can be considerable similarities between the movement of terrorist property and the laundering of criminal property: some terrorist groups are known to have well established links with organized criminal activity. However, there are two major differences between terrorist property and criminal property. More generally:

  • often only small amounts are required to commit individual terrorist acts, thus increasing the difficulty of tracking the terrorist property;

  • terrorists can be funded from legitimately obtained income, including charitable donations, and it is extremely difficult to identify the stage at which legitimate funds become terrorist property.

  1. This Policy provides direction to the Company staff on the approach and management of AML/CTF within the Company and supports management’s objective of mitigating the following financial crime risks:

  • money laundering risk;

  • terrorist financing risk;

  • fraud risk;

  • international financial sanctions risk.

  1. This Policy applies to all individuals working at all levels within the Company, including managers, CEO, employees, contractors, homeworkers, part-time and fixed-term workers, all of whom are collectively referred to as staff in this document.

  2. The Company’s CEO provides direction to, and oversight of, the AML/CTF strategy as well as applies a risk-based approach across the business.

  3. The Company enforces policy with zero tolerance for money laundering or terrorist financing activities and ensures it knows who its customers are and also who it is going into business with. Such activity is more commonly known as Know Your Customer (KYC).

  4. The Company has set out robust internal processes and procedures to help meet KYC requirements as well as trained its staff in AML/CTF awareness and how to spot potentially suspicious activity.

RISK-BASED APPROACH

  1. The Company applies a risk-based approach to managing the risks presented by the business, taking into account legislation and industry guidance as applicable.

  2. CEO is responsible for ensuring an AML/CTF risk assessment is completed and regularly reviewed. The risks assessed should help determine the strength of the Company’s policies and procedures and control systems in place to help prevent and detect such money laundering, terrorist financing and other financial crime activity.

  3. The risk-based approach takes the most cost effective and proportionate way to manage and mitigate money laundering, terrorist financing and related risks. The CEO assesses these financial crime risks presented by:

  • customer risk – specific categories of customers and the resulting business relationships;

  • payment risk – payment methods offered and the degree to which their specific characteristics are vulnerable to ML/TF threats;

  • geographical risk – the risks posed by geographical factors;

  • technological risk – risks with technology used by the Company (how susceptible is it to money laundering or terrorist financing?);

  • employee risk – the risks posed by employees of the Company.

  1. The CEO is responsible for:

  • design and implementation of controls to manage and mitigate those risks;

  • monitoring and seeking to improve the operation of these controls; and

  • recording what has been done for audit and evidence purposes.

  1. The Company recognizes that risks change over time and will continually and regularly update its risk management procedures as part of its overall AML/CTF risk management framework.

KNOW YOUR CUSTOMER MEASURES

  1. Know Your Customer (hereinafter KYC) measures applicable to customers are proportionate to the risk level they present.

  2. KYC must not be seen as a process or a checklist exercise to simply collect customer information. In addition to customer information gathering, KYC enables each customer and business relationship to be fully assessed and the financial crime risk fully understood to determine if the risk presented is acceptable for the Company.

  3. Staff interacting with the customers are obliged to perform the duties regarding the identification and verification of the identity of the customer, record keeping and escalating unusual circumstances or suspicions to the CEO.

  4. CEO is responsible for assessment of data and documentation collected by staff or submitted by the customer and final decision on the acceptability of the business relationship.

  5. Detailed KYC procedure including standard and enhanced customer due diligence measures are described by internal procedures complementary to the Policy.

  6. The results of actions taken to identify and verify the customer identity are stored in the customer files.

  7. The Company is prohibited from carrying out transactions and establishing or continuing business relationships when it has no possibilities to fulfil the KYC measures in this Policy:

  • when the customer fails to submit the data confirming his identity;

  • when the customer submits not all the data or where the data is incorrect.

INVESTIGATION OF SUSPICIOUS ACTIVITY

  1. After the Company accepts the business relationship with the customer staff monitors the customer activity and business relationship and informs CEO regarding any indications of unusual or suspicious activity.

  2. The Company is not regulated by AML/CTF laws and regulations, therefore it does not have an obligation to report suspicious activity to the Financial Intelligence Unit (FIU). However, in order to manage ML/TF risks the Company investigates unusual or suspicious activity of its customers in order to mitigate the risks by applying enhanced due diligence measures or ceasing unacceptable business relationships.

  3. The Company keeps results and conclusions relating to investigation of customers’ activity, monetary operations and transactions.

SANCTIONS SCREENING

  1. The Company takes measures to ensure that customers with whom a business relationship is established are not subject to international financial sanctions:

  • all payments from customers are collected via licensed payment or credit institutions and only in fiat currency (the Company does not accept cash or virtual currencies);

  • in the event of higher risk customers or suspicious activity, the Company screens its customers against publicly available United Nations, European Union, the Office of Foreign Assets Control (OFAC) sanctions lists.

  1. Information leading to fuzzy matches is investigated further, for example where the match is related to a name which can be deemed as popular, and is compared against the other information that is collected at point of registration. In case of any confirmed matches to sanctions lists, such customers are declined the services of the Company.

  2. The copy of screening results, even in case of negative results (“no hit”, “no match found”, or similar) are kept in the customer files.

TRAINING

  1. All staff members when they join the Company are made aware, through training program, of:

  • the risks of money laundering and terrorist financing, other financial crime risks;

  • Company’s policies and procedures relating to AML/CTF framework;

  • the Company’s procedures in how to recognize and deal with potential money laundering or terrorist financing suspicious transactions or activity.

  1. Staff training on AML/CTF is carried out at least annually for all staff, and details of the training are recorded (training material, participants list).

RECORD KEEPING

  1. The Company retains the following records from an AML/CTF perspective:

  • records of customer identification data and documents – for five years after the end of the customer relationship;

  • sanctions screening results – for five years after the end of the customer relationship;

  • details of customer transactions – for five years from the date of the relevant transaction;

  • details of actions taken in respect of internal suspicion investigation – for five years after the end of the relevant customer relationship;

  • records of AML/CTF trainings – for five years after the training delivery.