Anti-Money Laundering (AML) Policy
1. Purpose
- Money laundering
- Terrorist financing
- Fraudulent financial activity
- Tax evasion
- Sanctions violations
- Illicit fund transfers
The Platform operates as a digital entertainment service and does not function as a bank, financial institution, or money transmission service.
2. Risk Based Approach
- User risk classification
- Transaction monitoring
- Geographic risk assessment
- Behavioral analytics
- Enhanced due diligence for high risk accounts
Risk levels may include:
- Low Risk
- Medium Risk
- High Risk
- Prohibited
3. Customer Identification (KYC)
- Government issued ID
- Selfie verification
- Date of birth confirmation
- Bank account and UPI verification
Enhanced Due Diligence (EDD) for High Risk Accounts:
- Proof of address
- Tax ID number
- Source of funds declaration
- Additional documentation
- Failure to complete verification may result in withdrawal denial.
4. Age Verification
- Suspicious age misrepresentation may result in permanent suspension.
- The Platform may use AI or document verification tools.
5. Transaction Monitoring System
- Rapid Coin purchases
- High value single transactions
- Multiple transactions in a short period
- Circular gifting between accounts
- Self gifting behavior
- Linked device/account clusters
- Sudden Diamond spikes
- Geographic inconsistencies
- Repeated small withdrawals (structuring)
Automated risk scoring systems may be used.
6. Suspicious Activity Indicators
Examples of suspicious behavior include:
- Viewer and Creator collusion
- Gifting funded by stolen cards
- Artificial Diamond farming networks
- Account farming rings
- VPN masking for region bypass
- Use of multiple payment cards across accounts
- Abnormal chargeback frequency
- Sudden behavior changes after long inactivity
7. Withdrawal Controls
The Platform may:
- Impose daily and monthly withdrawal limits
- Place temporary holds (up to 30 days)
- Conduct manual review of high payouts
- Reverse Diamonds linked to chargebacks
- Freeze suspicious balances
Withdrawals are not guaranteed and remain subject to compliance approval.
8. Sanctions & Restricted Jurisdiction
The Platform may restrict or block users from:
- Sanctioned countries
- High risk financial jurisdictions
- Regions restricted by international regulations
We may screen users against:
- Government sanctions lists
- Politically exposed persons (PEP) lists
- Terrorism watchlists
9. Payment Fraud & Chargeback Protection
If fraudulent payments are detected:
- Coins may be revoked.
- Corresponding Diamonds may be deducted.
- Related accounts may be suspended.
- Withdrawals may be reversed.
The Platform reserves the right to recover losses.
10. Record Keeping
The Platform maintains:
- Transaction logs
- KYC records
- Withdrawal history
- Device fingerprinting data
- Risk scoring records
Records may be retained for 5–7 years or as required by law.
11. Reporting Obligations
Where legally required, the Platform may:
- Report suspicious activity to authorities
- Provide data to law enforcement
- Comply with court orders or regulatory requests
The Platform may act without notifying the user if prohibited by law.
12. Agency AML Controls
Agencies are prohibited from:
- Operating off platform payment schemes
- Guaranteeing fixed earnings
- Conducting pooled prize events
- Coordinating artificial gifting rings
Agency accounts may undergo enhanced monitoring.
13. Internal Controls
The Platform implements:
- Role based data access control
- Segregation of financial duties
- Audit logs
- Internal review procedures
- Periodic risk assessments
Compliance officer oversight (recommended)
14. Employee Training (Recommended for Growth)
The Company may conduct:
- Fraud detection training
- AML awareness training
- Data protection training
- Incident reporting training
15. Penalties For Violations
- Freeze funds
- Permanently ban accounts
- Forfeit virtual balances
- Pursue civil recovery
- Report to authorities
No compensation will be provided for forfeited funds.
16. Policy Updates
This AML Policy may be updated to reflect:
- Regulatory changes
- Business model changes
- Risk environment changes
Continued use of the Platform constitutes acceptance.