AML Policy

JungleSkins and the website jungleskins.io (the "Site") are owned and operated by F.N. FACTORY NEW TECHNOLOGIES LTD, a company registered in the Republic of Cyprus under registration number HE 497685, with its registered office at MITSI BUILDING 3, Floor 2, Flat/Office 206, Archiepiskopou Makariou III 1-7, 1065 Nicosia, Cyprus ("JungleSkins", "we", "us" or "our").

We are committed to the highest standards of integrity in our operations. This Anti-Money Laundering ("AML") Policy sets out the measures we apply to prevent the Site from being used for money laundering, terrorist financing, sanctions evasion or other financial crime. It forms part of our Terms of Use.

1. Objective of the policy

The objective of this policy is to protect the Site, our users and the wider financial system against money laundering, terrorist financing and other financial crime. It sets out how we identify, assess and manage these risks, and it applies to our employees, contractors and partners, and to every user of the Site.

2. Governance and oversight

The Company designates an AML Compliance Officer ("AMLCO"), who is responsible for implementing this policy, overseeing the measures described in it and reporting suspicious activity. The AMLCO reports directly to the Company's senior management. Senior management reviews the policy and its effectiveness at least once a year and whenever our services, risks or the law change.

3. Legal and regulatory framework

This policy is designed in line with:

• the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007 of the Republic of Cyprus (Law 188(I)/2007), as amended;
• Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, as amended, including by Directive (EU) 2018/843; and
• the restrictive measures (sanctions) adopted by the European Union and the sanctions of the United Nations Security Council.

4. Risk-based approach

We assess the money laundering and terrorist financing risks of our users, transactions, payment and deposit methods and the countries involved, and we apply measures in proportion to that risk. Higher-risk situations receive enhanced scrutiny; we do not disclose the specific thresholds or indicators we use, so that they cannot be circumvented.

5. Customer verification (Know Your Customer)

Every account is linked to a Steam account. In addition, identity verification may be required on a risk-based basis, including:

• before a withdrawal is processed;
• when your deposits, withdrawals or play exceed thresholds set by us;
• when your activity does not match your profile or shows signs of risk; and
• at any other time when we consider it necessary to comply with the law or this policy.

When verification is required, we may ask for:

• a valid government-issued photo identity document, such as a passport, national identity card or driving licence;
• a selfie, to confirm that the identity document belongs to you; and
• proof of address, such as a utility bill or bank statement issued within the last three months.

Enhanced due diligence

For higher-risk users and transactions, including where a user is a politically exposed person, we may also ask for information and evidence about the source of the funds or skins you use on the Site and about the source of your wealth. We keep the information we hold about higher-risk users up to date and review their activity more closely, so that changes in behaviour or circumstances are identified promptly.

Until verification is complete, we may suspend withdrawals, deposits or other activity on your account. If you do not provide the information we request, or if we cannot verify it, we may close your account in accordance with our Terms of Use. Personal data collected for verification is handled in accordance with our Privacy Policy.

6. Transaction monitoring

Every withdrawal is checked automatically against a per-account allowance, which caps the total value that the account can withdraw; withdrawals above it are held for staff review. Staff can also restrict withdrawals on an account or freeze it. When staff review a withdrawal or an account, they look in particular for:

• unusual volume or frequency of activity that is inconsistent with a user's profile;
• deposits followed by withdrawals with little or no genuine play;
• the use of payment methods, skins or locations associated with a high level of risk;
• complex or unusually structured transactions that appear designed to conceal the origin of funds;
• splitting larger amounts into smaller transactions to avoid thresholds;
• transfers of value between accounts, including through collusion in games or giveaways, and the use of multiple accounts; and
• payments from third parties, or activity linked to persons under sanctions or legal investigation.

Flagged activity is investigated and, where warranted, escalated to the AMLCO and reported to the competent authorities.

7. Sanctions screening

Where you pay with a payment method, the payment provider screens the payment against sanctions lists. We screen every user we verify (see section 5) against the sanctions lists of the European Union, the United Nations and the US Office of Foreign Assets Control (OFAC).

We do not provide services to persons or entities subject to sanctions, or to anyone using the Site from a Restricted Country listed in section 14 of our Terms of Use. If we find that funds or skins are connected with criminal activity, we block or hold the transaction and handle it under section 8.

8. Reporting suspicious activity

When our monitoring systems or staff identify a potentially suspicious transaction or activity, it is promptly escalated to the AMLCO for analysis. If the AMLCO determines that there are reasonable grounds to suspect money laundering or terrorist financing, the activity is reported to the Unit for Combating Money Laundering (MOKAS), the Financial Intelligence Unit of the Republic of Cyprus, or to another competent authority. The law may prevent us from telling you that a report has been made.

We may suspend activity on an account, and withhold balance and items, while an investigation is open or when a competent authority instructs us to.

9. Training and awareness

Our employees and contractors receive training on this policy and on anti-money laundering procedures, with an emphasis on recognising suspicious behaviour and using our monitoring tools. Training is repeated regularly so that our staff keep up with changes in the law and in best practice.

10. Record keeping and audits

We keep records of customer identification and verification and of transactions for at least five years after the end of our business relationship with a user or the date of an occasional transaction, or for longer where the law or a competent authority requires it. These records are stored securely and are accessible only to authorised personnel. We review the effectiveness of this policy and our controls regularly through internal audits.

11. Contact

We remain vigilant in identifying, monitoring and reporting suspicious activity to safeguard the integrity of the Site. For questions about this policy, or to report suspicious activity, contact us at [email protected].