Anti-Money Laundering Policy

Anti-Money Laundering Policy

Effective as of 01 10 2024

Last updated on 01 10 2024

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This This Know Your Customer Policy (“AML Policy”) is an integral part of the legal procedure of Skiller Games Limited (“Skiller”) and it is an integral part of Skiller’s Terms and Conditions. In order to be able to use the services offered by Skiller, every user of Skiller’s platform and services (“User”) needs to have declared to have read and agreed with these conditions.

Money laundering as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person’s or companies action;
• The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Money Laundering also encompasses the illicit act of funding terrorism. The challenges in the fight against money laundering are vast, and potential threats exist in every corner of the world. Financial services firms, regulators and law enforcement agencies alike work very hard to stay ahead of increasingly sophisticated criminals that seek to exploit the global financial system.

Skiller’s mission is to serve as a trusted partner by responsibly providing financial services that enable growth and economic progress. Consistent with this goal, Skiller is committed to the fight against money laundering.

Skiller AML Procedure

In order to comply with any applicable AML laws, Skiller shall be entitled performs all the required measures in accordance with applicable law and regulations. The AML policy is being fulfilled within Skiller by means of the following:

• Know your customer policy and due diligence
• Obtaining User Information
• Monitoring User activity
• Record keeping
• Communication with Competent Authorities
• Risk Assessment and Suspension of Users

User Due Diligence

Because of Skiller’s commitment to the AML and KYC policies, each User has to finish a verification procedure. Before Skiller starts any cooperation with the User, Skiller ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any user, customer or counterparty are taken. Skiller as well applies heightened scrutiny to Users, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.

User Information

During the process of registration, each User provides personal information, specifically: full name; date of birth; country of origin; and complete residential address. 

In case of suspicious actions of the User to verify personal information Skiller has the right to request the following documents: A User sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:

• Current valid passport (showing the first page of the local or international passport, where the photo and the signature are clearly visible); or
• Driving license which bears a photograph; or
• National identity card (showing both front and back pages);
• Documents proving current permanent address (such as utility bills, bank statements, etc.) containing the User’s full name and place of residence. These documents should not be older than 3 months from the date of filing.

Monitoring User activity

In addition to gathering information from the Users, Skiller continues to monitor the activity of every User to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with legitimate business or the usual User’s transaction history known from User activity monitoring.

Record keeping

Records must be kept of all transaction data and data obtained for the purpose of identification, as well as of all documents related to money laundering topics (e.g. files on suspicious activity reports, documentation of AML account monitoring, etc.). Those records are kept for a minimum of 7 years after the account is closed.

Communication with Competent Authorities

Skiller recognizes its obligation to cooperate with and support regulators and law enforcement agencies in their efforts to prevent, detect and control financial crime, and to comply with AML laws and regulation to close off the financial channels that money launderers and terrorist organizations use for illicit purposes.

Risk Assessment and Suspension of Users

While assessing the risks, Skiller applies the risk-based approach. It means that Skiller has an understanding of the AML risks to which it is exposed and applies AML measures in a manner and to an extent which would ensure mitigation of these risks. This flexibility enables Skiller to focus its resources and take enhanced measures in situations where the risks are higher.

To prevent money laundering, Skiller reserves the right to suspend any User’s operation, which can be regarded as imposing risk to an illegal or, may be related to money laundering in the opinion of Skiller at its sole discretion.

Third Party Verification

In order to conduct such verification process and/or background checks, in accordance with Skiller’s AML policy, Skiller may perform inquiries, directly or indirectly through third party service providers that Skiller considers necessary to verify User identity or to prevent fraud, suspicious activity, misidentification, money laundering or any other prohibited activity. Skiller reserves the right to take any action Skiller deems necessary with respect to the outcome of such inquiries. Users hereby acknowledge that Skiller shall have the right to investigate Users in case Skiller determines User to be risky or suspicious.