Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CTF)

1. Introduction

In order to ensure a safe environment for the users of its services, BackspinGames has developed this Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy.

This policy complies with applicable laws and regulations in the eligible jurisdictions where BackspinGames operates and supports the implementation of a risk-based approach to activities related to money laundering (AML) and terrorism financing (CTF).

BackspinGames works with identity verification providers (KYC) and payment service providers (hereinafter referred to as "Providers"), which are regulated entities and also comply with applicable laws and regulations in the eligible jurisdictions of BackspinGames.

2. Scope

This policy applies to all BackspinGames personnel, including employees, contractors, consultants, and third parties involved in AML/CTF-related activities. Specifically, it applies to employees involved in payments, fraud prevention, customer support, and regulatory compliance.

3. Risk-Based Approach

BackspinGames is committed to implementing a risk-based approach to AML/CTF activities. We will identify, assess, and manage the risks associated with our activities, products, services, clients, client transactions, and geographical locations.

4. Risk Assessment

BackspinGames will conduct periodic risk assessments to identify, evaluate, and manage risks related to AML/CTF. These assessments will consider the following factors:

• Products and services offered;
• Profile of BackspinGames' clients;
• Frequency, size, and complexity of client transactions;
• Geographical locations of our clients;
• Jurisdictions where BackspinGames operates;
• Specific money laundering or terrorism financing risks associated with individual clients or groups;
• Flow of funds within and outside the organization;
• Organizational structure of BackspinGames;
• Effectiveness of internal controls;
• Other relevant factors.

5. Policies and Procedures

BackspinGames will develop, implement, and maintain policies and procedures that include:

• Due diligence procedures for clients (KYC);
• Continuous monitoring of client transactions;
• Internal record-keeping and reporting requirements;
• Training and awareness programs;
• Sanctions list verification;
• Reporting of suspicious activities;
• Independent testing of internal controls;
• Audit and compliance functions;
• Manual and automated internal controls.

These policies and procedures will be managed by both BackspinGames and its Providers.

6. Politically Exposed Persons (PEPs)

Individuals who hold or have held prominent public functions, as well as those related to them, are considered Politically Exposed Persons (PEPs). PEPs, like other high-risk clients, will be subject to enhanced due diligence procedures to mitigate the AML/CTF risks they may present.

7. Sanctions Lists

BackspinGames and its Providers will verify clients and transactions against applicable sanctions lists, in compliance with relevant laws and regulations.

8. KYC (Know Your Customer) Procedures

BackspinGames reserves the right to request the following information from users:

• First name;
• Last name;
• Postal address;
• Date of birth;
• Email address;
• Password;
• Mobile phone number.

Additionally, we may request additional documentation to comply with security and regulatory requirements, such as:

• Utility bill not older than 90 days;
• Bank or credit card statement not older than 90 days;
• Canceled check.

If documentation is required before approving a withdrawal, a request will be sent to the customer by email. If no response is received within 14 days, a final notice will be sent. If the customer does not provide the requested documentation, their BackspinGames account will be suspended.

9. Monitoring and Review

BackspinGames will continuously review and evaluate the effectiveness of its AML/CTF policy and adjust its procedures in line with industry best practices and applicable regulatory changes.

10. Reporting and Record-Keeping

BackspinGames and its Providers will report suspicious activities to the relevant authorities as required by law and maintain records of all AML/CTF-related activities in accordance with applicable regulations.

11. Training and Awareness

BackspinGames will provide annual training programs to ensure that all its personnel understand AML/CTF policies and procedures and the risks associated with these activities.

12. Anti-Corruption and Anti-Bribery

BackspinGames maintains the highest ethical standards in its business relationships. We apply a zero-tolerance policy against any form of bribery, corruption, fraud, or unethical conduct among our employees and third parties acting on our behalf.

13. Conclusion

BackspinGames is committed to implementing a risk-based approach to AML/CTF activities, complying with applicable laws and regulations in the jurisdictions where it operates. We will periodically evaluate and review our policies to ensure their effectiveness and up-to-date compliance.