Anti-Money Laundering &
Counter-Terrorist Financing Policy

1. Purpose & Commitment

The Company is committed to:

• Preventing money laundering, terrorist financing, and other financial crimes;
• Complying with all applicable AML, CTF, and sanctions laws;
• Maintaining effective internal controls proportionate to the nature and risk of its business.

The Company maintains a risk-based compliance program consistent with industry standards.

2. Scope of Services

• Digital game publishing and distribution
• Payment facilitation using real-world currency only
• No issuance, custody, exchange, or operation of:
  • Virtual currencies
  • Cryptocurrencies
  • Stablecoins
  • Stored-value wallets

The Company is not a bank and not a financial institution, except to the extent applicable law may deem certain activities regulated.

3. Applicable Laws & Regulations

The Company’s AML/CTF framework aligns with, where applicable:

4. Risk-Based Approach

The Company applies a risk-based approach, considering:

• Customer type (User vs. Merchant)
• Geographic location
• Transaction volume and frequency
• Payment methods
• Behavioral indicators

Enhanced controls are applied to higher-risk scenarios.

5. Customer Due Diligence (CDD)

6. Know Your Customer (KYC)

The Company relies on:

• Payment processors and regulated financial partners for primary KYC verification;
• Internal checks to identify inconsistencies, suspicious behavior, or fraud indicators.

The Company may request additional documentation where required by law or payment partners.

7. Sanctions & Watchlist Screening

8. Transaction Monitoring

The Company monitors transactions for red flags, including but not limited to:

• Unusual transaction volumes
• Repeated failed payment attempts
• High-risk jurisdictions
• Chargeback or fraud patterns
• Attempts to circumvent platform controls

Suspicious activity may result in account suspension or termination.

9. Reporting & Escalation

Where required by applicable law or payment partner obligations, the Company may:

• File Suspicious Activity Reports (SARs) through appropriate channels;
• Cooperate with law enforcement or regulatory authorities;
• Provide transaction records in response to lawful requests.

10. Record Keeping

The Company retains AML-related records for a period consistent with applicable law, typically at least five (5) years, unless a longer period is legally required.

11. Training & Awareness

Relevant personnel receive periodic training on:

• AML/CTF obligations
• Fraud detection
• Escalation procedures
• Sanctions compliance

12. Independent Review

The Company periodically reviews and updates this Policy to:

• Reflect changes in laws or business operations;
• Address emerging financial crime risks;
• Maintain alignment with payment partner requirements.

13. Enforcement & Disciplinary Measures

Violations of this Policy may result in:

• Account suspension or termination;
• Reporting to authorities;
• Internal disciplinary actions, where applicable.

14. Data Protection

All AML-related data processing is conducted in accordance with the Company’s Privacy Policy and Data Processing Addendum (DPA). Personal data is processed solely for compliance and security purposes.

15. Governing Law

This Policy shall be governed by the laws of the State of Washington, United States, without regard to conflict-of-law principles.

16. Contact