Aml Policy

Introduction

Spinjili maintains an Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) policy to prevent the platform from being used for money laundering, terrorist financing, or other illegal financial activities. This policy applies to all user accounts, transactions, and activities conducted through the Spinjili platform and forms an integral part of our Terms of Service.

Objectives

• Prevent the use of Spinjili services for money laundering, terrorist financing, or related crimes.
• Comply with applicable AML/CTF laws and regulations in relevant jurisdictions and with international standards.
• Implement Know Your Customer (KYC) procedures and ongoing due diligence.
• Adopt a risk-based approach to assess and mitigate ML/TF risks across products, channels, and geographies.
• Monitor transactions and user activity and report suspicious activity to the appropriate authorities.
• Provide ongoing training to employees on AML/CTF responsibilities and procedures.

Definitions

• Money Laundering (ML): The process of concealing the illicit origin of criminally derived property or funds, including placement, layering, and integration stages.
• Terrorist Financing (TF): The provision or collection of funds, by any means, with the intention or knowledge that they will be used to carry out terrorist acts or to support terrorist organizations or individuals.
• Know Your Customer (KYC): Verification of the identity and risk profile of customers, including ongoing monitoring.
• Source of Funds (SoF) and Source of Wealth (SoW): Information demonstrating the origin of funds and the overall wealth of the customer used to assess risk and legitimacy.
• Politically Exposed Person (PEP): An individual who holds or has held a prominent public function and may present higher ML/TF risk.

Governance and Compliance

The Board of Spinjili holds ultimate responsibility for AML/CTF compliance. Spinjili has appointed a Money Laundering Reporting Officer (MLRO) responsible for the day-to-day implementation, oversight, and management of this policy and related procedures. The MLRO operates with sufficient independence and resources to perform these duties and reports to senior management and the Board on AML/CTF matters.

Know Your Customer and Due Diligence (KYC/CDD & EDD)

Spinjili uses a risk-based approach to customer due diligence (CDD) and enhanced due diligence (EDD) to identify, verify, and monitor customers in line with legal requirements.

CDD (Standard Due Diligence)

• All users must register an account and provide information consistent with the verification requirements described in this policy.
• Identity and age verification will be conducted using reliable, independent sources, including government-issued documents. Verification may involve third-party providers for identity screening and sanctions/PEP checks.
• We aim to understand the purpose and intended nature of the customer relationship to assess ML/TF risk.

EDD (Enhanced Due Diligence)

• EDD applies to higher-risk scenarios, including but not limited to: PEPs or associates, customers from high-risk jurisdictions, unusually large or complex activity, or red flags identified by monitoring systems.
• EDD measures may include additional identity information, verification of the source of funds and wealth, enhanced ongoing monitoring, and management-level approval to commence or continue the business relationship.

Ongoing Monitoring

Spinjili conducts ongoing monitoring of customer activity and transactions to identify suspicious or unusual behavior. The depth of monitoring is aligned with the customer’s risk profile and updated periodically to reflect risk changes.

Onboarding and Acceptance Policy

Spinjili reserves the right to refuse or suspend a customer’s account or to terminate access at any time where acceptance criteria are not met or AML/CTF concerns arise. Grounds for refusal or suspension include, but are not limited to:

• Failure to provide satisfactory identification or documentation for CDD/EDD purposes.
• Submission of false, misleading, or forged information.
• Use of means intended to conceal location or identity, or involvement with restricted or sanctioned jurisdictions per internal policy.
• Identification as a PEP with unacceptable risk that cannot be mitigated; inability to establish SoF/SoW.
• Suspicion of ML/TF or other criminal activity; concerns regarding legitimacy of funds.
• Inability to form a reasonable belief in the customer’s identity or beneficial ownership.

Spinjili reserves the right to suspend or close accounts at its sole discretion where necessary to comply with AML/CTF obligations or to protect the integrity of the business.

Transaction Monitoring and Sanctions Screening

Spinjili employs a combination of automated and manual controls to detect ML/TF risks across all activities. Key monitoring aspects include:

• Screening of customers and transactions against relevant sanctions and restricted lists; blocking or restricting activities involving identified parties or jurisdictions.
• Blockchain analytics for cryptocurrency deposits and withdrawals to assess wallet risk, flag illicit ties, and identify links to sanctioned or illicit activity.
• Monitoring for unusual patterns, such as atypical size, frequency, or layering of transactions, and detection of attempts to structure or obscure the origin of funds.
• Controls to detect mixing or tumbling activities; enforcement actions including potential account suspension or enhanced due diligence where indicated.
• Thresholds for withdrawal or activity that trigger additional verification or monitoring, as defined in the internal risk framework.
• Monitoring of deposit-to-activity correlation to identify funds that are not consistent with legitimate use.

Red Flag Indicators

• Inadequate or inconsistent information during onboarding or KYC checks.
• Multiple accounts with overlapping or conflicting customer details without legitimate justification.
• Transactions unusual in size, timing, or nature for the profile.
• Cryptocurrency addresses linked to illicit activity or high-risk channels.
• Rapid, repeated deposits and withdrawals with limited engagement or obvious gaming activity.
• Reluctance to provide SoF/SoW information when requested.
• Use of VPNs or tools to obscure location, especially from restricted areas.
• Alerts from analytics tools or adverse media about the customer.

Escalation and Action

When red flags are triggered or suspicious activity is detected, the MLRO will be notified for investigation. Outcomes may include enhanced due diligence, account restrictions, or reporting to authorities as required by law.

Risk Assessment

Spinjili adopts a risk-based approach to AML/CTF compliance. The risk assessment considers factors including customer risk (geography, behavior, verification status), product/service risk (gaming and cryptocurrency features), geographical risk, and interface risk related to non-face-to-face onboarding. The risk assessment is reviewed at least annually or upon significant changes to the business or regulatory environment.

Record Keeping

Spinjili maintains records of all AML/CTF information for a minimum period of five (5) years from the end of the customer relationship or the date of the last transaction, whichever is later. Records include identification data, transaction details, correspondence, internal AML/CTF reports, training records, and any regulatory communications. Records are stored securely and are accessible to competent authorities upon lawful request.

Reporting Suspicious Activity

Any employee who suspects ML/TF activity must promptly report to the MLRO. The MLRO will investigate all internal reports. If there are reasonable grounds to suspect ML/TF, a Suspicious Activity Report (SAR) will be filed with the relevant financial intelligence authority in accordance with applicable law. Employees will not disclose the existence of a SAR to the customer or third parties, in accordance with legal restrictions. Spinjili cooperates fully with law enforcement and regulatory authorities, subject to applicable legal constraints.

Training and Awareness

Spinjili provides regular AML/CTF training to personnel in management, operations, payments, and compliance roles. Training covers applicable AML/CTF laws, internal policies, risk awareness, identification of red flags, and procedures for reporting suspicious activity. Training is conducted at least annually, with additional sessions as needed based on risk or regulatory developments.

Data Protection and Privacy

Spinjili processes personal data in accordance with applicable data protection laws. Personal data collected for AML/CTF purposes will be retained for five (5) years from the end of the customer relationship or last transaction, or longer if required by law. Access to such data is restricted to authorized personnel and may be disclosed to competent authorities upon lawful request. Customers may exercise rights to access, rectify, or erase their data in compliance with applicable data protection laws, and consent for processing may be withdrawn where legally permissible without compromising the legality of processing conducted prior to withdrawal.