Last updated: January 15, 2025
MOXIE SKINS LTD is committed to combating money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy establishes procedures to detect, prevent, and report suspicious activities in compliance with applicable laws and regulations including the Money Laundering Regulations, Bank Secrecy Act, and international AML standards.
Our AML compliance program adheres to:
- Financial Action Task Force (FATF) recommendations
- EU Anti-Money Laundering Directives (4th & 5th AMLD)
- UK Money Laundering Regulations 2017
- US Bank Secrecy Act and USA PATRIOT Act
- Local financial intelligence unit requirements
- OFAC sanctions and screening requirements
- Steam account verification and authentication
- Identity verification through Steam OAuth
- Verification of Steam account age and standing
- Basic profile information collection
- Transaction pattern monitoring
Required when transaction limits exceed $5,000 USD or suspicious patterns are detected:
- Government-issued photo identification
- Proof of address (utility bill, bank statement)
- Source of funds verification
- Enhanced transaction monitoring
- Beneficial ownership identification (for entities)
- Additional screening against sanctions lists
- Enhanced screening for PEPs and their associates
- Senior management approval for PEP relationships
- Continuous monitoring of PEP accounts
- Source of wealth verification
- Real-time transaction screening
- Pattern recognition and anomaly detection
- Velocity checks and frequency analysis
- Geographic risk assessment
- Cross-referencing with sanctions lists
- Machine learning-based risk scoring
Daily Limits:
- Standard Users: $2,500 USD
- Verified Users: $10,000 USD
- Enhanced Users: $25,000 USD
Monthly Limits:
- Standard Users: $15,000 USD
- Verified Users: $50,000 USD
- Enhanced Users: $150,000 USD
- Unusual trading patterns or frequency
- Transactions just below reporting thresholds
- Multiple accounts from same IP or device
- Rapid buy-sell cycles with minimal price differences
- Large cash deposits or withdrawals
- Transactions with high-risk jurisdictions
- Inconsistent customer behavior
- Use of multiple payment methods
- Requests to modify transaction details
We screen all users and transactions against:
- OFAC Specially Designated Nationals (SDN) List
- EU Consolidated List of Persons and Entities
- UN Security Council Sanctions List
- UK HM Treasury Sanctions List
- National sanctions lists (Canada, Australia, etc.)
- Law enforcement watchlists
- Real-time screening at account creation
- Daily batch screening of existing users
- Transaction-level screening
- Fuzzy matching algorithms
- Manual review of potential matches
- Immediate blocking of confirmed matches
- Single transactions ≥ $10,000 USD
- Related transactions ≥ $10,000 USD in 24 hours
- Any transaction flagged by monitoring systems
- Cash transactions ≥ $3,000 USD
- Cryptocurrency transactions ≥ $3,000 USD
- Any amount involving sanctioned parties
- Initial alert generation by monitoring system
- Level 1 review by compliance analyst
- Level 2 review by senior compliance officer
- Investigation and documentation
- SAR filing within regulatory timeframes
- Ongoing monitoring of reported accounts
- SARs filed within 30 days of detection
- CTRs for cash transactions ≥ $10,000
- FBAR reporting for foreign accounts
- FinCEN Form 8300 for cash payments
- Coordination with law enforcement
Required Records (Minimum Retention Periods):
Transaction Records: 7 years
Customer Identification: 5 years after account closure
SARs and Supporting Documentation: 5 years
Training Records: 3 years
AML Program Documentation: 3 years
Sanctions Screening Results: 5 years
Record Security:
- Encrypted storage with access controls
- Regular backups and disaster recovery
- Audit trails for all access
- Secure disposal of expired records
Staff Training Requirements:
- Initial AML training for all employees
- Annual refresher training
- Role-specific training programs
- Updates on regulatory changes
- Testing and certification
- Record keeping of training completion
Training Topics:
- AML laws and regulations
- Red flag identification
- Customer due diligence procedures
- Sanctions screening requirements
- Reporting obligations
- Record keeping requirements
AML Compliance Officer Responsibilities:
- Oversee day-to-day AML compliance
- Ensure staff training and awareness
- Monitor regulatory changes
- Conduct risk assessments
- Review and update AML procedures
- Liaison with regulators and law enforcement
Board and Senior Management:
- Approve AML policies and procedures
- Ensure adequate resources
- Review regular compliance reports
- Oversee independent testing
- Respond to regulatory findings
Annual Risk Assessment considers:
Customer Risk Factors:
- Customer type and profile
- Geographic location
- Transaction patterns
- Account age and history
- Payment methods used
Product/Service Risk Factors:
- Digital asset trading risks
- Cross-border transactions
- High-value item trading
- Anonymity features
- Speed of transactions
Geographic Risk Factors:
- High-risk jurisdictions
- Sanctions countries
- Non-cooperative jurisdictions
- Countries with weak AML controls
Account Actions for AML Violations:
Immediate Actions:
- Account freezing or suspension
- Transaction blocking
- Withdrawal restrictions
- Enhanced monitoring
Escalation Procedures:
- Warning notices and compliance requirements
- Account limitations and restrictions
- Account closure and fund forfeiture
- Law enforcement referral
- Civil and criminal penalties
For AML compliance matters:
AML Compliance Officer: aml@PoshSkins.com
Suspicious Activity Reports: sar@PoshSkins.com
Legal Department: legal@PoshSkins.com
Address: [TBD]