Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CFT)

1. Purpose and Scope

GamePayments is a Virtual Asset Service Provider (VASP) offering infrastructure for receiving, holding, and withdrawing USDT (TRC-20) on behalf of business clients ("Product Owners").

This policy is designed in accordance with FATF Recommendations (in particular Recommendations 10, 15, 16) to prevent the Platform from being used for:

• Money Laundering (ML)
• Terrorist Financing (TF)
• Circumventing sanctions regimes
• Weapons of Mass Destruction Proliferation Finance

This policy applies to: all Company staff, all Product Owners, and their end users.

2. Customer Verification (KYB — Know Your Business)

Before any product is activated on the Platform, the Product Owner must complete KYB. The Company applies a Risk-Based Approach (RBA):

Data Category	Information Collected
Legal Entity	Name, type (LLC, sole trader, JSC, etc.), country of registration and operations
Business Activity	Business description (min. 50 chars), category, expected monthly USDT volume
Contact Person	Full name, corporate email, job title
Compliance Declarations	Acceptance of ToS and this AML policy, source-of-funds declaration

KYB decisions are made manually by the Company's compliance team within 2–5 business days.

Grounds for KYB denial or product suspension:

• Activity falls into a prohibited category (see Section 3)
• Incomplete, inaccurate, or contradictory information provided
• Client or related persons appear on sanctions lists (OFAC, EU, UN)
• High risk score according to internal risk model

3. Prohibited Activities

Using the Platform is prohibited for the following activities:

• Illicit drug trafficking
• Gambling without a valid licence in the jurisdiction of operation
• Sale of weapons, ammunition, or explosives
• Unlicensed financial pyramids and Ponzi schemes
• Copyright or patent infringing services
• Human trafficking or any related activity
• High-risk unlicensed cryptocurrency exchanges
• Transaction anonymisation (mixer/tumbler services)
• Activities involving fully sanctioned jurisdictions (DPRK, Iran, Syria, Cuba, etc.)

The Company reserves the right to freeze funds and terminate the agreement upon discovery of prohibited activities, with immediate notification to relevant regulatory authorities.

4. Withdrawal Policy and Cooldowns

Withdrawal controls are the primary tool for preventing "layering" — the second stage of the classic money-laundering cycle (placement → layering → integration). The Platform applies the following control layers:

4.1 Global Rules (apply to all organisations)

Control	Parameter	Rationale
New organisation cooldown	48 hours after KYB approval	Gives the compliance team time to spot issues before real money leaves the platform
Active product status	Status must be "Active"	Products under review, suspended, or rejected cannot withdraw funds

4.2 Configurable Per-Product Controls

Control	Default	Recommended Values
Withdrawal interval	0 (no restriction)	60 min — standard; 1440 min (24 h) — high-risk categories
Daily withdrawal cap (rolling 24 h)	No limit	$10,000 — standard; $1,000 — for new products
Internal transfer interval	0 (no restriction)	5–15 min — sufficient to prevent circular layering between sub-accounts

4.3 Policy Error Codes

When a policy control is triggered, the API returns standardised error codes:

Code	HTTP	Description
ORG_KYB_NOT_APPROVED	403	Organisation KYB not yet approved
NEW_ORG_COOLDOWN	429	48-hour new-org cooldown is active
WITHDRAWAL_COOLDOWN	429	Withdrawal interval has not elapsed
DAILY_LIMIT_EXCEEDED	429	Rolling 24-hour withdrawal cap exceeded
TRANSFER_COOLDOWN	429	Sub-account transfer interval has not elapsed

A 429 response includes a retry_after field (ISO 8601 UTC) indicating when the operation is permitted.

5. Transaction Monitoring

The Company conducts automated and manual transaction monitoring. Triggers for manual review:

• Single withdrawal exceeds $10,000 USDT
• Multiple withdrawals to the same address within 24 hours
• Destination address previously flagged as associated with illicit activity (public blockchain analytics)
• Sudden spike in a product's transaction volume (more than 5× the weekly average)
• Withdrawal immediately following a large deposit with no discernible business logic

6. Reporting and Escalation

Where there are reasonable grounds to suspect money laundering or terrorist financing, the Company shall (upon obtaining the relevant licences) file a Suspicious Activity Report (SAR/STR) with the competent financial authority of its jurisdiction of incorporation.

Prior to regulatory registration, the Company maintains an internal register of suspicious events and notifies the Chief Compliance Officer within 24 hours of discovery.

7. Sanctions Screening

The Company screens all organisations against the following lists at KYB and on each data update:

• OFAC SDN List (United States)
• EU Consolidated Sanctions List
• UN Security Council Consolidated List
• FATF High-Risk and Under Increased Monitoring jurisdictions

USDT destination addresses are checked against available public blockchain analytics databases. Transactions linked to sanctioned addresses are blocked automatically.

8. Record Keeping

All records of transactions, KYB applications, webhooks, API requests, and compliance decisions are stored in encrypted form for a minimum of 5 years from the date of the client's last activity, in line with FATF Recommendation 11.

9. Staff Training

All staff with access to financial data or who take compliance decisions must complete mandatory AML/CFT training at least once per year. New employees complete introductory training within 30 days of joining.

10. Policy Updates

This policy is reviewed at least annually or whenever there is a material change in the regulatory environment. Product Owners receive email notification of changes at least 14 days before they take effect.

11. Compliance Contact

For AML/CFT, sanctions, or suspicious-transaction enquiries, please contact:

📧 compliance@gamepayments.tech
🌐 Terms of Service · AML Policy