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Anti-Money Laundering (AML) Policy of WinCrate

1 . Introduction

WinCrate operates under the corporate entity WinCrate LLC. This Anti-Money Laundering (AML) Policy outlines our commitment to preventing the misuse of our platform for money laundering activities. This policy establishes clear guidelines and procedures to ensure compliance with relevant laws and regulations, safeguarding the integrity of our financial operations.

2 . Objective of the Policy

The primary objective of this policy is to ensure robust security measures for all users of WinCrate. We conduct regular account verifications to authenticate customer details and validate deposit methods. This process is essential for confirming the accuracy of user information and mitigating the risk of illicit use of payment methods. Our policy establishes a comprehensive framework to combat money laundering (ML) and to assess and mitigate ML risks through appropriate resources and controls.

WinCrate is dedicated to upholding stringent anti-money laundering (AML) standards, requiring strict adherence from both management and employees to prevent the misuse of our services for money laundering purposes. By maintaining high AML standards, we protect our users and our business from the adverse effects of financial crimes.

3 . Regulatory Frameworks

Our AML program is designed to comply with the following regulatory frameworks:

EU Directive 2015/849: Prevention of the use of the financial system for the purposes of money laundering.
EU Regulation 2015/847: Information accompanying transfers of funds.
EU Regulations on Sanctions and Embargoes: Including measures against individuals and restrictions on goods and technology.
Belgium's Law of 18 September 2017: Prevention of money laundering and limitation of cash use.

We continuously monitor changes in regulatory requirements to ensure our policies and procedures remain compliant with the latest legal standards. This proactive approach helps us to maintain a robust defense against money laundering activities.

4 . Definition of Money Laundering

Money laundering involves:

The conversion or transfer of assets derived from criminal activity to conceal their illicit origin or assist individuals to evade legal consequences.
The concealment or misrepresentation of the true nature, source, location, disposition, movement, rights, or ownership of assets from criminal activity.
The acquisition, possession, or use of assets with knowledge of their criminal origins.
Participation, facilitation, or attempts to commit the aforementioned actions.
Understanding these definitions is crucial for identifying potential money laundering activities and implementing effective preventive measures. Our staff is trained to recognize the signs of money laundering and to take appropriate action when suspicious activities are detected.

5 . AML Organizational Structure

WinCrate has established a robust AML organizational structure:

D Level Management: The highest level of responsibility for ML prevention.
AML Compliance Officer (AMLCO): Oversees the enforcement of AML policies and procedures, under the direct supervision of the Compliance Officer, who reports to the CEO.
The AMLCO is responsible for implementing AML policies, conducting risk assessments, and ensuring compliance with regulatory requirements. This role is critical in maintaining the integrity of our financial operations and protecting our users from financial crimes.

6 . Policy Implementation Requirements

Significant modifications to WinCrate's AML policy require approval from D Level Management. This ensures that any changes are thoroughly reviewed and align with our commitment to preventing money laundering. The approval process involves a comprehensive evaluation of the proposed changes and their potential impact on our AML compliance.

7 . Enterprise-Wide Risk Assessment (EWRA)

As part of our risk-based approach, we conduct an annual Enterprise-Wide Risk Assessment (EWRA) to identify and comprehend specific AML risks related to our business operations. This assessment considers products, services, clientele, transactions, delivery channels, and geographic locations. The EWRA helps us to prioritize our AML efforts and allocate resources effectively.

8 . Minimum Standards

WinCrate has stringent Know-Your-Customer (KYC) standards requiring thorough due diligence on each customer before granting access to receive items. This includes identification and verification of their identity, representatives, and beneficial owners using reliable and independent sources compliant with AML regulations.

Our KYC process involves several steps:

Customer Identification: Collecting and verifying information such as name, address, date of birth, and identification documents.
Verification: Using reliable and independent sources to confirm the accuracy of the information provided by the customer.
Ongoing Monitoring: Continuously monitoring customer transactions and activities to detect and prevent suspicious behavior.

9 . Customer Identification and Verification (KYC)

Formal customer identification upon entering commercial relationships is crucial. This involves:

Submission of identification documents (passport, ID card, driving license) with clear visibility and legibility.
Proof of address through a recent utility bill or bank statement.

Our KYC process also includes:

Enhanced Due Diligence (EDD): For high-risk customers, we conduct more thorough checks to ensure compliance with AML regulations.
Risk Assessment: Assessing the risk level of each customer based on factors such as transaction volume, geographic location, and business activity.
Record Keeping: Maintaining accurate records of customer information and verification processes for at least ten years.

10 . Ongoing Customer Due Diligence

Periodic risk-based reviews are conducted for higher-risk customer categories to maintain updated customer data. The AML team scrutinizes dedicated files, and relationship managers conduct thorough periodic KYC reviews. This ensures that we have accurate and up-to-date information about our customers, enabling us to detect and prevent money laundering activities.

11 . Ongoing Transaction Monitoring

WinCrate employs a three-level transaction monitoring system:

First Line of Control: Partnering with reputable Payment Service Providers with strong AML policies.
Second Line of Control: Mandating due diligence on transactions involving customers, players, or representatives.
Third Line of Control: Automated risk-based monitoring of transactions for high-risk customers.

Our transaction monitoring process includes:

Real-Time Monitoring: Using advanced technology to monitor transactions in real-time and detect suspicious activities.
Pattern Analysis: Analyzing transaction patterns to identify unusual or potentially suspicious behavior.
Alert Management: Generating alerts for transactions that meet predefined criteria for further investigation.

12 . Internal Controls and Suspicious Transactions Reporting

WinCrate has internal procedures to guide staff on reporting suspicious transactions. The AML team analyzes reports of atypical transactions and decides whether to report to the Financial Intelligence Unit (FIU) or terminate business relations. Our internal controls include:

Suspicious Activity Reports (SARs): Filing SARs with the FIU for transactions that are deemed suspicious.
Training and Awareness: Educating staff on how to recognize and report suspicious activities.
Compliance Reviews: Regularly reviewing our internal controls to ensure they are effective and up-to-date.

13 . Procedures and Record Keeping

AML regulations and KYC standards are translated into operational procedures accessible on WinCrate's Intranet. Data obtained for identification purposes is retained for a minimum of ten years, and transaction records are maintained for at least ten years. Our record-keeping practices include:

Document Management: Ensuring that all identification and verification documents are stored securely and can be retrieved when needed.
Data Retention: Retaining customer and transaction data for the required period to comply with regulatory requirements.
Audit Trails: Maintaining detailed audit trails to document the steps taken during the KYC and transaction monitoring processes.

14 . Training for Due Diligence

WinCrate implements comprehensive AML training programs for staff, including:

Mandatory AML Training: Required for all employees to ensure they understand our AML policies and procedures.
Role-Specific Training: Tailored training for employees based on their roles and responsibilities.
Continuous Education: Ongoing training to keep staff informed of the latest regulatory developments and best practices.

Our training programs cover topics such as:

AML Regulations: Understanding the legal and regulatory framework for AML compliance.
Risk Assessment: Identifying and assessing AML risks associated with our business operations.
Transaction Monitoring: Detecting and reporting suspicious activities.

15 . Auditing

Regular internal audits assess and report on AML activities to ensure compliance and effectiveness of the AML program. Our auditing process includes:

Internal Audits: Conducted by our internal audit team to evaluate the effectiveness of our AML controls.
External Audits: Independent audits performed by external auditors to verify compliance with AML regulations.
Audit Reports: Detailed reports outlining audit findings and recommendations for improvement.

16 . Roles and Responsibilities

To ensure the effective implementation of our AML policy, we have clearly defined roles and responsibilities for our staff:

Board of Directors: Provides oversight and ensures that our AML policy aligns with our strategic objectives.
Senior Management: Responsible for implementing and enforcing our AML policy.
Compliance Officer: Manages the AML program and ensures compliance with regulatory requirements.
AML Compliance Officer (AMLCO): Oversees the day-to-day operation of the AML program.
Employees: Responsible for adhering to our AML policy and reporting suspicious activities.

17 . Risk-Based Approach

WinCrate adopts a risk-based approach to AML compliance, focusing our efforts on the areas of highest risk. This approach includes:

Risk Assessment: Identifying and assessing the AML risks associated with our business operations.
Risk Mitigation: Implementing controls and procedures to mitigate identified risks. Ongoing Monitoring: Continuously monitoring our operations to detect and address new or emerging risks.

18 . Customer Risk Assessment

Our customer risk assessment process includes:

Customer Profiling: Creating profiles for each customer based on their risk level.
Risk Scoring: Assigning a risk score to each customer based on factors such as transaction volume, geographic location, and business activity.
Enhanced Due Diligence (EDD): Conducting more thorough checks for high-risk customers.

19 . Transaction Risk Assessment

We assess the risk of transactions based on various criteria to identify potential money laundering activities. This process involves:

Transaction Patterns: Analyzing transaction patterns to detect anomalies such as unusually large or frequent transactions.
Geographic Risks: Considering the location of the transaction origin and destination, with higher scrutiny for transactions involving high-risk countries.
Customer Behavior: Monitoring changes in customer behavior that could indicate suspicious activities.
Transaction Types: Giving special attention to transactions that involve cash, international wire transfers, or other high-risk types.

20 . Enhanced Due Diligence (EDD)

For higher-risk customers and transactions, we implement Enhanced Due Diligence (EDD) measures which include:

In-Depth Investigations: Conducting more comprehensive background checks.
Source of Funds Verification: Confirming the origin of the customer’s funds.
Ongoing Monitoring: Increased frequency of transaction monitoring and regular reviews of customer profiles.
Senior Management Approval: Requiring approval from senior management for high-risk accounts and transactions.

21 . Customer Acceptance Policy

Our Customer Acceptance Policy (CAP) outlines the criteria for accepting customers, including:

Risk Profiling: Assessing new customers based on their risk profile.
Verification Processes: Ensuring all new customers undergo thorough KYC procedures.
Rejection Criteria: Establishing clear guidelines for rejecting customers who do not meet our AML standards or pose a high risk.

22 . Monitoring and Reporting Suspicious Activities

Monitoring and reporting suspicious activities is a key component of our AML framework. This includes:

Transaction Monitoring Systems: Using automated systems to monitor transactions in real-time and flag suspicious activities.
Suspicious Activity Reports (SARs): Filing SARs with the Financial Intelligence Unit (FIU) for transactions that meet specific criteria.
Employee Reporting: Training employees to identify and report suspicious activities to the AML compliance team.

23 . Internal Controls and Procedures

We have established a comprehensive set of internal controls and procedures to support our AML efforts:

Policy Enforcement: Ensuring all employees understand and comply with our AML policy.
Regular Audits: Conducting regular internal audits to evaluate the effectiveness of our AML controls.
Compliance Checks: Implementing routine compliance checks to identify and address any gaps in our AML procedures.

24 . Collaboration with Regulatory Authorities

WinCrate collaborates with regulatory authorities to ensure compliance with AML regulations and to support investigations into money laundering activities. This includes:

Information Sharing: Sharing relevant information with regulatory authorities as required by law.
Regulatory Reporting: Submitting regular reports to regulatory authorities to demonstrate our compliance efforts.
Cooperation in Investigations: Assisting regulatory authorities in investigations related to money laundering activities.

25 . Data Protection and Privacy

We are committed to protecting the privacy and confidentiality of our customers' information while complying with AML regulations. This includes:

Data Security Measures: Implementing robust data security measures to protect customer information.
Privacy Policies: Ensuring our privacy policies align with data protection laws and regulations.
Access Controls: Limiting access to customer information to authorized personnel only.

26 . Continuous Improvement

We are committed to continuously improving our AML program by:

Regular Reviews: Conducting regular reviews of our AML policies and procedures to ensure they remain effective and up-to-date.
Feedback Mechanisms: Implementing feedback mechanisms to gather input from employees and customers on how we can improve our AML efforts.
Innovation in AML Technology: Investing in new technologies and tools to enhance our ability to detect and prevent money laundering activities.

27 . Employee Roles and Responsibilities

Clearly defining employee roles and responsibilities is crucial for the effective implementation of our AML policy. This includes:

Board of Directors: Providing oversight and strategic direction for our AML program.
Senior Management: Ensuring the implementation and enforcement of AML policies and procedures.
Compliance Officer: Managing the AML program and ensuring compliance with regulatory requirements.
AML Compliance Officer (AMLCO): Overseeing the day-to-day operation of the AML program and reporting to senior management.
Employees: Adhering to our AML policies and procedures and reporting any suspicious activities.

28 . AML Communication and Awareness

Effective communication and awareness are essential for the success of our AML program. This includes:

Internal Communication: Regularly communicating AML policies and updates to all employees.
AML Awareness Campaigns: Conducting campaigns to raise awareness about the importance of AML compliance.
Training Programs: Providing comprehensive training programs to ensure all employees understand their roles and responsibilities in preventing money laundering.

29 . Whistleblowing Policy

We have established a whistleblowing policy to encourage employees to report any concerns related to money laundering activities without fear of retaliation. This includes:

Whistleblower Protection: Ensuring the protection of whistleblowers from any form of retaliation or discrimination.
Anonymous Reporting: Providing mechanisms for anonymous reporting of concerns.
Investigation Process: Ensuring all reported concerns are thoroughly investigated and appropriate action is taken.

30 . Conclusion

WinCrate is committed to maintaining the highest standards of anti-money laundering compliance. By implementing comprehensive AML policies and procedures, we aim to protect our users and our business from the risks associated with money laundering activities. Our commitment to continuous improvement ensures that we remain vigilant and proactive in our efforts to prevent financial crimes.

We recognize that the fight against money laundering is an ongoing process, and we are dedicated to staying ahead of emerging threats and adapting to changes in the regulatory landscape. Through collaboration with regulatory authorities, investment in technology, and a strong culture of compliance, we will continue to uphold the integrity of our platform and safeguard the interests of our customers and stakeholders.