Anti Money Laundering Policy
AML Policy of Phoenix Games For Deposits and Withdrawals
Introduction
Phoenix Games is operated by Ludus Limited, with its principal office located in the Cayman Islands. Company Registration Number: SG-412594.
At Phoenix Games, we are committed to upholding the highest security standards for our users and customers. To achieve this, a robust three-step verification process is implemented to ensure the identity of every customer. This process verifies that registered details are accurate and that deposit and withdrawal methods are not being misused or exploited for unlawful activities.
Our primary goal is to establish a comprehensive framework to combat money laundering (ML) and financing of illicit activities. We recognize that varying payment methods, nationalities, and withdrawal amounts necessitate specific safety measures.
Objectives of the AML Policy
Ensure all transactions on Phoenix Games are secure and transparent.
Minimize ML risks by implementing proactive measures and dedicated compliance efforts.
Adhere to international AML regulations and ensure effective Know Your Customer (KYC) processes.
Phoenix Games follows high standards of AML compliance and aligns with relevant laws, requiring both management and employees to enforce these standards to prevent misuse of its services for ML purposes.
Compliance Framework
The AML program of Phoenix Games adheres to the following regulatory guidelines:
EU Directives:
Directive 2015/849: Preventing the use of the financial system for ML and terrorism financing.
Regulation 2015/847: Information requirements for transfers of funds.
Global Best Practices:
Standards set by the Financial Action Task Force (FATF).
Additional international and local regulations governing AML.
Definition of Money Laundering
Money laundering refers to the process of concealing the origins of funds derived from criminal activities. It includes:
Converting or transferring property (e.g., money) to disguise its illicit origin.
Concealing the true nature, source, or ownership of property derived from illegal activity.
Using or acquiring property, knowing it originated from criminal activity.
Participating in activities that facilitate or abet money laundering.
Money laundering is considered an offense regardless of whether the activities generating illicit funds occurred domestically or internationally.
AML Structure at Phoenix Games
To combat money laundering, Phoenix Games has appointed:
General Management Oversight: Full management assumes responsibility for AML enforcement.
AML Compliance Officer (AMLCO): Directly responsible for implementing AML policies and procedures.
Verification Process
Step 1 Verification
Required for all users to process withdrawals, regardless of the transaction amount or method.
Users must complete a form with the following details:
Full name
Date of birth
Country of residence
Gender
Full address
Step 2 Verification
Triggered for deposits exceeding $2,000 USD or any withdrawal request.
Requires users to:
Submit a photo ID alongside a six-digit randomly generated number on a note.
Pass electronic data checks to confirm the accuracy of provided details.
If electronic verification fails, users must submit proof of residence (e.g., government-issued registration or utility bill).
Step 3 Verification
Mandatory for transactions exceeding $5,000 USD, including deposits, withdrawals, or transfers to another user above $3,000 USD.
Requires users to provide documentation for the source of wealth (SOW), such as:
Proof of business ownership.
Employment details.
Inheritance records.
Investment portfolios.
Know Your Customer (KYC) Process
Phoenix Games employs a stringent KYC policy to ensure customer identification and prevent fraudulent activity:
Identity Verification:
Users must provide a copy of their passport, ID card, or driver’s license alongside a handwritten note with a six-digit code.
A secondary photo showing the user's face is required.
Address Verification:
Proof of address must be provided via electronic checks or manual submission (e.g., recent utility bills or government correspondence).
Source of Funds Verification:
Users with transactions exceeding $5,000 USD must demonstrate the origin of their wealth.
Risk Management and Regional Categorization
Phoenix Games assesses risks based on geographical regions and categorizes them as follows:
Low Risk:
Standard three-step verification applies.
Medium Risk:
Stricter thresholds for verification:
Step 2: Triggered at $1,000 USD.
Step 3: Triggered at $2,500 USD.
High Risk:
High-risk regions are blocked from accessing the service.
Ongoing Transaction Monitoring
Phoenix Games monitors transactions at multiple levels:
First Line of Control:
Transactions are reviewed by trusted payment service providers with robust AML policies.
Second Line of Control:
Automated systems detect unusual activity (e.g., rapid deposits and withdrawals without gameplay).
AI systems flag suspicious transactions for manual review.
Third Line of Control:
High-risk accounts undergo thorough manual checks.
Suspicious activity is reported to relevant authorities.
Record Keeping
All customer identification and transaction records are securely stored for a minimum of 10 years in compliance with data protection regulations.
Training and Awareness
Phoenix Games ensures all employees undergo mandatory AML training to stay updated on the latest regulatory developments. Training includes:
Specialized AML sessions for finance-related roles.
Practical workshops conducted by AML specialists.
Auditing and Data Security
Regular internal audits are conducted to evaluate AML effectiveness. All customer data is encrypted and protected under applicable data protection laws, ensuring confidentiality and security.
Reporting Suspicious Transactions
Employees are instructed to immediately report any suspicious activity to the AML team. Based on the investigation:
Reports may be submitted to the Financial Intelligence Unit (FIU).
Business relations with suspicious customers may be terminated.
Contact Us
For questions or concerns about our AML and KYC policies:
Email: compliance@phoenixgames.io
If you have complaints regarding the checks conducted on your account:
Email: compliance@phoenixgames.io
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