AML / CTF Policy

Effective date: November 12, 2025

Contact: dev@asigames-europe.com • Website: https://asigames.online

This Anti-Money Laundering and Counter-Terrorist Financing Policy (“Policy”) sets out the measures ASI Games (“we”, “us”, “our”) implements to prevent money laundering, terrorist financing, and related financial crimes across our services, including developer payouts, virtual cards and transfers (where available).

1 Scope & Applicable Standards

We apply a risk-based AML/CTF framework aligned with FATF standards and relevant EU/UK laws and guidance, as applicable. This Policy applies to all users, partners, employees, contractors, and to all products and geographies where we operate.

2 Definitions

“Money laundering” is the process of concealing illicit origins of funds. “Terrorist financing” is providing or collecting funds to support terrorist acts or organizations. “Customer” includes studios, companies, and individuals using our services. “Beneficial owner” means the natural person(s) ultimately owning or controlling a customer.

3 Risk-Based Approach (RBA)

We assess inherent and residual risks across customers, geographies, products, delivery channels, and transactions. Controls and reviews scale with the risk rating (low/medium/high). Higher-risk relationships require enhanced due diligence and ongoing senior management oversight.

4 Customer Due Diligence (CDD)

Prior to activation, we collect and verify customer identity details (e.g., legal name, registration number, address, directors, UBOs). We verify beneficial ownership and control structures and understand the nature and purpose of the relationship.

5 Enhanced Due Diligence (EDD)

For high-risk cases (e.g., complex ownership, high-risk geographies, unusual transaction patterns), we apply EDD such as obtaining additional source-of-funds/source-of-wealth information, senior management approval, and more frequent reviews.

6 Sanctions, PEP & Adverse Media Screening

We screen customers and relevant parties against applicable sanctions lists and PEP databases and review adverse media. Matches are escalated to compliance; onboarding/continuation may be refused or restricted as required by law.

7 Ongoing Monitoring & Triggers

We monitor activity to detect unusual patterns (e.g., rapid inflows/outflows, structuring, circular transactions, activity inconsistent with the customer’s profile). Triggers include material changes in ownership, business model, geography, or transaction behaviour.

8 Suspicious Activity & Reporting

We investigate alerts and, where suspicion remains, file reports with competent authorities as required. Customers will not be informed where tipping-off restrictions apply. We may freeze, delay, or reject transactions pending review.

9 Record-Keeping

We retain KYC files, transaction records, screening and monitoring results, and reports for the legally required period (typically 5+ years, or longer where permitted/required). Records are stored securely and made available to regulators when lawfully requested.

10 Governance & Responsibilities

Our Board (or delegated committee) oversees AML/CTF compliance. A designated AML Officer is responsible for the day-to-day program, reporting, and liaison with authorities. All staff share responsibility for identifying and escalating potential issues.

11 Training & Awareness

Employees receive AML/CTF training at onboarding and periodically thereafter, tailored to role and risk. Training covers red flags, sanctions/PEP awareness, escalation channels, and record-keeping obligations.

12 Third Parties & Outsourcing

Where we use regulated payment, KYC or screening providers, we conduct due diligence and maintain oversight. Reliance on third parties does not relieve us of our AML/CTF obligations; ultimate accountability remains with ASI Games.

13 Data Protection & Confidentiality

Personal data collected for AML/CTF purposes is processed in accordance with our Privacy Policy and applicable data protection laws. Access is restricted to authorized personnel on a need-to-know basis.

14 Independent Review & Audit

We periodically assess the effectiveness of our AML/CTF program through internal reviews and, where appropriate, independent audits. Findings are tracked to closure with management oversight.

15 Consequences of Non-Compliance

Breach of this Policy may result in denial of onboarding, service suspension/termination, reporting to authorities, and civil/criminal penalties where applicable.

16 Policy Updates & Versioning

We may update this Policy to reflect legal or operational changes. The latest version and effective date will be published on our website. Material updates may be communicated via email or dashboard notice.

Questions about this Policy or to report a concern: dev@asigames-europe.com