Lastly updated 12/04/2023
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.
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.
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:
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:
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.
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.
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.
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).