KYC and AML policy

Lastly updated 12/04/2023

Introduction

This KYC and AML Policy (hereinafter referred to as “Policy”) is established by Trueplay Inventions Inc., a company duly registered and existing under the laws of Republic of Seychelles, a digital services provider specializing in the sphere of tokenization of reward systems and loyalty programs (hereinafter referred to as “Trueplay“, “we“, “us“, “our“). The purpose of this Policy is to outline Trueplay’s commitment to complying with the applicable KYC and AML laws, regulations, and best practices in Seychelles and internationally, in order to prevent money laundering, terrorist financing, fraud, and other illicit activities.

Policy Scope

This Policy applies to all customers, users, clients, partners, operators and affiliates (hereinafter collectively referred to as “Customers“) of Trueplay’s digital services related to the tokenization of reward systems and loyalty programs, TRUEPLAY Widget as well as other services and products made available for the Customers.

KYC Procedures

As may be required by the applicable laws Trueplay may practice risk-based KYC procedures to verify the identity of Customers and collect relevant information, including but not limited to:

• Customer Identification: Trueplay may require Customers to provide valid and up-to-date identification documents, such as passports, national IDs, corporate documents or other government-issued documents, and verify the authenticity of such documents through reliable and independent sources.

• Beneficial Ownership: Trueplay may identify and verify the beneficial ownership of legal entities or structures that are Customers, including their ultimate beneficial owners (UBOs), officers, directors, and other relevant persons, and collect the necessary documentation and information to establish their identity.

• Required permits and licenses: Trueplay may require Customers to provide valid confirmation that such Customers are duly licensed and/or obtained required permits to conduct their activities in particular jurisdictions.

• Risk Assessment: Trueplay may conduct risk assessments to determine the level of risk associated with each Customer, based on factors such as their country of residence, business activities, transaction volume, and other relevant risk indicators, and apply enhanced due diligence (EDD) measures for high-risk Customers.

• Ongoing Monitoring: Trueplay may continuously monitor Customers’ activities for any suspicious or unusual transactions or behaviors that may indicate money laundering, terrorist financing, fraud, or other illicit activities, and report such activities to the relevant authorities as required by law.

AML Procedures

As may be required by the applicable laws Trueplay may implement risk-based AML procedures to detect, prevent, and report money laundering, terrorist financing, fraud, and other illicit activities, including but not limited to:

• On-chain Transaction Monitoring: Trueplay may use sophisticated one-chain transaction monitoring tools and systems to detect and analyze patterns, trends, and anomalies in Customers’ transactions, including but not limited to transaction amount, frequency, destination, and source of funds to the extent it is possible in terms of blockchain transactions, and investigate and report any suspicious transactions to the relevant authorities as required by law.
• Sanctions Screening: Trueplay may screen Customers against global sanctions lists, including but not limited to United Nations (UN), European Union (EU), United States (US) and other relevant national and international sanctions lists, and prevent Customers from engaging in any transactions or activities that are prohibited by applicable sanctions laws.

• Reporting Obligations: Trueplay may be required to comply with all applicable AML laws and regulations in Seychelles, including but not limited to the Anti-Money Laundering Act, and report any suspicious transactions, designated transactions, or other reportable activities to the relevant authorities, such as the Financial Intelligence Unit (FIU), as required by law.

Record Keeping

Trueplay may be required to maintain accurate and complete records of all KYC and AML activities, including but not limited to identification documents, transaction data, risk assessments, investigation reports, and other relevant information, in accordance with applicable laws and regulations, and retain such records for the required period of time as specified by law.

Staff Training

Trueplay provides regular and ongoing training to its staff to ensure their understanding and compliance with this KYC and AML Policy. The training covers topics such as the importance of KYC and AML procedures, identification and verification of Customers, risk assessments, transaction monitoring, sanctions screening, reporting obligations, and record keeping. Trueplay also keeps its staff updated with the latest developments in KYC and AML laws, regulations, and best practices.

Compliance Monitoring

Trueplay establishes internal procedures and controls to monitor and assess the effectiveness of its KYC and AML procedures, and conduct periodic reviews to ensure compliance with this Policy and applicable laws and regulations. Any identified deficiencies or weaknesses in the KYC and AML procedures shall be promptly addressed and remediated.

Cooperation with Authorities

Trueplay shall cooperate fully with relevant authorities, such as the FIU, law enforcement agencies, and regulatory bodies, in their investigations and inquiries related to money laundering, terrorist financing, fraud, or other illicit activities. Trueplay shall provide timely and accurate information, documentation, and support as required by law.

Customer Due Diligence

Trueplay reserves the right to request additional information or documentation from Customers to fulfill its KYC and AML obligations, and may refuse or terminate its services to Customers who fail to provide satisfactory and sufficient information or who are found to be engaged in suspicious or illegal activities.

Compliance with EU Regulations and Directives

Trueplay acknowledges and understands that under certain conditions it may be subject to various European Union (EU) regulations and directives related to KYC and AML, including but not limited to the Fourth EU Anti-Money Laundering Directive (2015/849/EU), the Fifth EU Anti-Money Laundering Directive (2018/843/EU), the EU General Data Protection Regulation (2016/679/EU), and any other applicable EU laws and regulations. 

In addition to the KYC and AML procedures outlined in this Policy, Trueplay under certain circumstances may also be required to comply with any additional customer due diligence requirements imposed by EU regulations and directives. In such a case Trueplay may be required to fulfill its reporting obligations to EU authorities, including but not limited to the Financial Intelligence Units (FIUs) of EU member states, as required by applicable EU regulations and directives. This may include reporting suspicious transactions, conducting internal investigations, and maintaining proper records in accordance with EU laws and regulations.

Amendments to the Policy

This Policy may be amended or updated by Trueplay at any time without prior notice, in compliance with changes in applicable laws, regulations, or best practices. Customers shall review this Policy periodically to stay informed of any changes.

Conclusion

Trueplay is committed to preventing money laundering, terrorist financing, fraud, and other illicit activities, and complying with applicable KYC and AML laws, regulations, and best practices. By using Trueplay’s digital services related to the tokenization of reward systems and loyalty programs, TRUEPLAY Widget as well as other services and products made available by Trueplay, Customers acknowledge and agree that they shall cooperate with Trueplay in terms of compliance with this KYC and AML Policy as well as adhere to this KYC and AML Policy (where applicable).