Anti-Money Laundering & Know Your Customer Policy

Effective Date: April 7, 2026

Summary: Eternel Games is committed to preventing the use of its Platform for money laundering, terrorist financing, or other illicit activities. This policy outlines the identity verification, transaction monitoring, and record-keeping procedures we maintain.

1. Scope & Legal Framework

This policy applies to all users of the Eternel Games platform (“Platform”) and all services operated by Eternel Games Ltd (“Operating Entity”). Our AML/KYC program is designed in accordance with:

  • The UK Proceeds of Crime Act 2002 (POCA)
  • The UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
  • EU Anti-Money Laundering Directives (where applicable to EU users)
  • US Bank Secrecy Act (BSA) and FinCEN regulations (where applicable to US users)

Eternel Games Ltd, as the Operating Entity, is responsible for implementing and maintaining these procedures.

2. Know Your Customer (KYC)

2.1 When KYC Is Required

Identity verification is mandatory before a player can process their first withdrawal. Additionally, KYC may be triggered at any time based on risk indicators (see Section 3).

2.2 Document Requirements

Standard KYC verification requires:

  • Government-issued photo ID — Passport, national ID card, or driver’s licence. Must be valid (not expired) and clearly legible.
  • Proof of address — Utility bill, bank statement, or government correspondence dated within the last 3 months, showing name and residential address.

2.3 Enhanced Due Diligence (EDD)

Enhanced verification may additionally require:

  • Source of funds declaration — Documentation showing the origin of deposited funds (e.g., bank statements, pay slips, tax returns).
  • Source of wealth documentation — For high-value accounts, evidence of overall wealth origin.
  • Video verification — A live video call to confirm identity in high-risk situations.

2.4 Verification Process

Documents are reviewed by our compliance team. We aim to complete standard KYC within 24 hours of submission. During verification, withdrawal requests are held. If verification fails or documents are insufficient, we will contact the player with specific requirements.

Accounts that fail to complete KYC when required will have withdrawal functionality suspended until verification is completed.

3. Risk-Based Approach

We apply a risk-based approach to customer due diligence, assigning risk levels based on multiple factors:

3.1 Risk Indicators

  • Transaction patterns — Unusually large or frequent deposits, rapid deposit-withdrawal cycling, structured transactions
  • Geographic risk — Players from jurisdictions with higher AML risk ratings (per FATF guidance)
  • Account behavior — Minimal gameplay relative to transaction volume, multiple accounts linked to the same individual
  • Deposit thresholds — Cumulative deposits exceeding defined thresholds trigger enhanced review

3.2 Tiered Due Diligence

  • Standard — Government photo ID + proof of address (required for all withdrawals)
  • Enhanced — Source of funds documentation (triggered by risk indicators or deposit thresholds)
  • Ongoing monitoring — Continuous review of high-risk accounts with periodic re-verification

4. Sanctions Screening

All players are screened against applicable sanctions lists including:

  • UK HM Treasury sanctions list
  • EU consolidated sanctions list
  • US OFAC Specially Designated Nationals (SDN) list
  • UN Security Council sanctions list

Screening is performed at account creation, at KYC verification, and periodically thereafter. Players identified on any sanctions list will have their accounts immediately frozen and reported to the relevant authorities.

5. Transaction Monitoring

We maintain automated systems to monitor all financial transactions on the Platform, including deposits, withdrawals, tournament entries, and prize payouts. Monitoring includes:

  • Deposit-withdrawal patterns — Flagging accounts that deposit and withdraw with minimal gameplay activity
  • Velocity checks — Detecting unusual frequency or volume of transactions
  • Structuring detection — Identifying transactions designed to avoid reporting thresholds
  • Blockchain analytics — For cryptocurrency deposits, monitoring for connections to high-risk wallets, mixers, or sanctioned addresses

All transactions are recorded with a full audit trail, including timestamps, amounts, transaction type, and resulting balance. This audit trail is maintained in the Platform’s transaction ledger.

6. Suspicious Activity Reporting

Where we identify or suspect money laundering, terrorist financing, or other financial crime, we will:

  • File a Suspicious Activity Report (SAR) with the UK National Crime Agency (NCA) as required under POCA
  • File a Suspicious Transaction Report (STR) with relevant authorities in other jurisdictions where required
  • Freeze or suspend the account pending investigation, without prior notice to the player
  • Cooperate with law enforcement and regulatory authorities

Under UK law, we are prohibited from informing a player that a SAR has been filed or that their account is under investigation for suspected financial crime (“tipping off” offence under POCA s.333A).

7. Record Retention

In accordance with MLR 2017 and applicable AML regulations, we retain:

  • KYC documents — Copies of identity documents and proof of address for a minimum of 5 years after the end of the business relationship
  • Transaction records — Complete financial transaction history for a minimum of 5 years after the transaction date
  • Risk assessments — Customer risk profiles and due diligence records for a minimum of 5 years
  • Correspondence — All compliance-related communications for a minimum of 5 years

Records may be retained for longer periods where required by law or where ongoing legal proceedings or regulatory investigations necessitate retention.

8. Player Obligations

By using the Platform, you agree to:

  • Provide accurate and truthful information during registration and KYC verification
  • Promptly provide additional documentation when requested for due diligence purposes
  • Not use the Platform for money laundering, terrorist financing, or any other illicit purpose
  • Not allow any third party to use your account or deposit funds on your behalf
  • Notify us immediately if you become aware of any suspicious activity involving your account

Failure to comply with these obligations may result in account suspension, termination, and forfeiture of account balance in accordance with our Terms of Service.

9. Contact

For questions about our AML/KYC procedures or to submit verification documents, contact us at [email protected].

For compliance and regulatory inquiries: [email protected].

Eternel Games LLC · Wyoming, USA — Intellectual Property & Legal

Eternel Games Ltd · Company No. 17139657 · Registered in England and Wales

128 City Road, London, EC1V 2NX, United Kingdom

Contact: [email protected]