KYC & AML Policy
MTCGAME CO. LTD, ("MTCGAME", "we", "us", "our", and Company) has developed an Anti-Money Laundering and Anti-Terrorist Financing Policy ("AML Policy") in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering and terrorist financing. Our policies and procedures meet or exceed legislative requirements in Hong Kong and reflect how we manage money laundering and terrorist financing risks posed to MTCGAME in order to provide a robust, compliant platform.
The Proceeds of Crime and Terrorist Financing Act
In accordance with the prescribed legislative requirements set forth in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA"), our Company is required to fulfill certain record keeping, identification, and reporting requirements. Our Company has chosen to implement and maintain a compliance regime which includes, but is not limited to:
-Establishing robust internal policies, procedures and controls that strive to combat any attempted use of MTCGAME's products or services for illegal or illicit purposes.
-Executing Know Your Customer (“KYC”) procedures on all customers* to identify them as required by the PCMLFTA;
-Assessing of our risks as it relates to money laundering and terrorist financing;
-Following all applicable record retention requirements as required by the PCMLFTA;
-Monitoring transactions for potentially suspicious and attempted suspicious activities for the purposes of filing Suspicious Transaction Reports ("STR") or Attempted Suspicious Transaction Reports ("ASTR");
-Maintaining and providing written, ongoing compliance training for our employees to ensure their understanding of their responsibilities under the PCMLFTA and Regulations in Hong Kong; and,Regular reviews of our compliance regime to test its effectiveness related to money laundering and terrorist financing every two years.
Ongoing Monitoring of Business Relationships
Business relationships are established once a client has an account with your organization. At MTCGAME an active account, and therefore a business relationship, is defined as when a customer conducts two or more commercial transactions, with the exclusion of closed loop gift card purchases, within a 12 month period. Therefore for business relationships MTCGAME must:
-Determine the identity of the individual
In addition to the above, MTCGAME adheres to the following regulatory requirements:
Risk-rating all business relationships and amending their risk-rating if the need arises;Conducting ongoing monitoring of the business relationship as determined by the risk-rating (high/low) assigned to the customer; and,Keeping a record of the measures that we have taken to monitor the relationship and the information we obtained as a result.If necessary, we may require our customers to provide additional documentation or information to confirm source of funds for the purpose of the transaction.
Our system employs a combination of automated and manual monitoring procedures with an appropriate escalation process based on risk. MTCGAME's compliance staff will review any transactions that trigger a system alert and determine if the activities are within the customers\’ stated activity and/or normal usage behavior before being completed. In some cases, MTCGAME will ask the customer for additional information such as documents to prove identity, payment receipt, documents to prove the payment card.
Know Your Customer Processes
Prior to a customer being able to perform a transaction using MTCGAME's products or services, MTCGAME, must identify the customer, known as Know Your Customer ("KYC"), in accordance with applicable regulations. MTCGAME has a policy which requires all customers to be "verified" in the following circumstances:
Information that we may collect in order verify and authenticate a customer or beneficial owner:
Mobile phone number;
Full legal name;
Unique device information
Proof of identity or passport
Additional information or documentation at the discretion of our compliance team.
Ongoing Monitoring of Business Relationships
If in the course of reviewing and monitoring, we identify unexplainable or unusual patterns or activity, we will work to obtain further information so that questions surrounding the suspicious activity are satisfactorily answered. MTCGAME may also report the activity internally to our CCO who is required to maintain a record/log of all internally reported and perform a review to determine if an STR is to be filed with FINTRAC.
If MTCGAME cannot reach a clear understanding of the customer's identity, or the sources and movement of funds, it may result in their account being permanently closed. This will be followed by terminating the business relationship and blacklisting the account owner to prevent them from re-opening a new account.
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