Anti-Money Laundering (AML) Policy

1. Introduction

This website is operated by PepeGames, a limited liability company incorporated under the applicable jurisdiction, with its registered office at Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of the Comoros.

This Anti-Money Laundering (AML) Policy sets forth our commitment to preventing the use of our services for money laundering, terrorist financing, fraud, and other financial crimes.

2. Purpose of the AML Policy

The purpose of this AML Policy is to ensure a high level of security for our users and to ensure compliance with applicable anti-money laundering regulations.

To that end, we implement a multi-step verification process designed to:

• Verify users' identities

• Prevent the unauthorized use of payment methods

• Detect and prevent suspicious financial activities

The website maintains internal procedures, monitoring tools, and controls designed to minimize AML-related risks.

3. Regulatory Framework

This AML Policy is aligned with international best practices, including, but not limited to:

• Recommendations issued by the Financial Action Task Force (FATF)

• Applicable regional and international AML legislation

• Internal Risk Assessments at the Corporate Level

4. Definition of Money Laundering

Money laundering includes, among other things:

• Concealment or conversion of proceeds from criminal activities

• Use of financial systems to conceal the illegal source of funds

• Use of third-party identities or forged documents

• Structuring or splitting transactions to conceal the source of funds

Money laundering may be established even if the underlying criminal activity occurred outside the user's jurisdiction.

5. AML Organizational Structure

• A General Administration oversees the development and implementation of the AML Policy

• O AML Compliance Officer (AMLCO) is responsible for implementation, monitoring, reporting, and employee training

6. Verification Process

Step 1 – Basic Identification

PepeGames may request document verification before any withdrawal request.

Includes:

• Full name

• Date of Birth

• Country of residence

• Full home address

7. Know Your Customer (KYC)

KYC procedures may include:

• Official government-issued photo ID

• Selfie with ID and verification code

• Proof of address issued within the last three (3) months

• Cross-checking information across multiple databases

8. Geographic Risk-Based Verification

• Low-risk regions: Standard verification limits apply

• Medium-risk regions: Enhanced due diligence and lower limits may be applied

• High-risk jurisdictions: Users may be restricted or subject to enhanced due diligence, in accordance with applicable laws and regulations

9. Transaction Monitoring & Payment Method Controls

Automated and manual monitoring tools are used to detect suspicious activity, including:

• Unusual Transaction Patterns

• Inconsistent account behavior

• Multiple currency conversions

For the purpose of preventing money laundering and fraud, the Withdrawals are processed exclusively using the same payment method used for the deposit.

Withdrawals are not permitted to third-party payment methods or to payment instruments that have not previously been used for deposits.

All flagged transactions are reviewed by properly trained compliance professionals.

10. Enterprise-Wide Risk Assessment (EWRA)

A corporate risk assessment is conducted annually to analyze risks related to:

• Services Offered

• User Behavior

• Geographical Location

• Payment Methods

• Emerging threats, including risks associated with cryptocurrencies

11. Continuous Monitoring & Controls

The AML structure operates under a model of three lines of defense:

• First Line: Payment service providers with internal AML controls

• Second Line: Continuous monitoring conducted by operational teams

• Third Line: Independent audits and investigations conducted by senior compliance staff

Suspicious activities may be escalated and reported to the appropriate authorities, as required by law.

12. Reporting of Suspicious Transactions

Employees are required to report any suspicious or unusual transactions to the AML team.

These reports may result in:

• Internal investigation

• Account Suspension or Closure

• Submission of a report to the relevant Financial Intelligence Unit (FIU)

13. Record Retention

Records are maintained in accordance with applicable legal and regulatory requirements:

• User identification records: up to 10 years after the business relationship has ended

• Transaction records: up to 10 years after the transaction is completed

All data is stored securely and encrypted.

14. Training

All employees involved in financial transactions receive mandatory AML training, including:

• Initial Onboarding Training

• Ongoing workshops and case studies

• Periodic certifications and refresher courses

15. Audit

Internal audits are conducted periodically to assess the compliance and effectiveness of AML measures, as well as to recommend improvements when necessary.

16. Data Privacy

User data is treated as confidential and disclosed only when:

• Required by law, or

• Necessary to prevent criminal activity

17. Contact Information

For questions regarding this AML/KYC Policy or security issues, please contact us at: [email protected]