KYC/AML Policy

Know Your Customer (KYC) Effective Controls Policy

  1. Introduction

The purpose of this KYC policy is to establish a framework for verifying the identity of customers who use Token Tiger LLC.

This policy ensures compliance with relevant legal and regulatory requirements, helps prevent fraudulent activities, and promotes a secure and trustworthy gaming environment.

  1. Objectives
    • Verify the identity of customers.
    • Monitor and report suspicious activities.
    • Ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
    • Protect the website from fraudulent activities.
    • Safeguard customer data in accordance with privacy laws.
  2. Scope

This KYC policy applies to all customers who register, participate, and conduct transactions on Token Tiger LLC. It includes the processes for customer identification, verification, and ongoing monitoring.

  1. Customer Identification Program (CIP)

4.1    Information Collection

During registration, customers must provide the following information:

  • Full name
  • Date of birth
  • Residential address
  • Email address
  • Phone number
  • Government-issued photo ID (e.g., passport, driver’s license)
  1. 2.   Verification Process
  • Document Verification: Customers must upload a government-issued photo ID for verification. The document will be checked for authenticity and validity using VERIFF’s identity verification service.
  • Address Verification: Customers may be required to provide additional documents, such as utility bills or bank statements, to verify their residential address.
  • Electronic Verification: The provided information will be cross-checked against public and private databases to confirm identity and address.

4.3    Risk-Based Approach

Customers will be categorized based on their risk profiles:

  • Low Risk: Customers with consistent behavior and low transaction volumes.
  • Medium Risk: Customers with irregular transactions or higher volumes.
  • High Risk: Customers from high-risk jurisdictions or with significant changes in behavior.
  1. Ongoing Monitoring

5.1    Transaction Monitoring

  • All transactions will be monitored for unusual or suspicious activities.
  • Transactions exceeding predefined thresholds will trigger further verification and investigation.

5.2    Periodic Review

  • Customer information will be periodically reviewed and updated to ensure accuracy.
  • High-risk customers will undergo more frequent reviews.
  1. Record Keeping
  • All customer identification and verification records will be securely stored for at least five years.
  • Records of transactions and interactions with customers will also be maintained for the same period.
  1. Reporting
    1. 1. Suspicious Activity Reports (SARs)
  • Any suspicious activities identified during monitoring will be reported to the relevant authorities in compliance with regulatory requirements.

7.2    Compliance Officer

  • A dedicated Compliance Officer will oversee the implementation of the KYC policy, handle regulatory reporting, and ensure ongoing compliance.
  1. Data Protection and Privacy
  • Customer data will be handled in compliance with GDPR and other relevant privacy laws.
  • Strong encryption and access controls will be implemented to protect customer information.
  1. Employee Training
  • Regular training sessions will be conducted for employees to ensure they understand KYC requirements and can effectively implement the policy.
  • Employees will be trained to identify and report suspicious activities.
  1. Policy Review and Updates
  • The KYC policy will be reviewed annually and updated as necessary to comply with new regulations and emerging best practices.
  • Feedback from stakeholders, including customers and employees, will be incorporated into the policy review process.
  1. Customer Communication
  • Customers will be informed about the KYC policy during registration and whenever significant changes are made.
  • Clear instructions and support will be provided to customers to complete the KYC process.
  1. Approval and Authority
  • The KYC policy is approved by senior management and is enforced across all levels of the organization.
  • The Compliance Officer has the authority to make necessary decisions to ensure the policy’s effective implementation.