AML Policy

Anti-Money Laundering (AML) Policy - fierspin.com
For the deposit and withdrawal of cash.

Introduction
The objective of the AML policy of fierspin.com is to ensure maximum security for all our users and clients, for which a two-step account verification is conducted to confirm the identity of our clients. The purpose of this is to ensure that the data of the registered person is correct and that the payment methods used are not stolen or used by third parties, which creates a common basis for combating money laundering. We also consider that depending on citizenship, origin, payment method, and withdrawal method, different security measures need to be taken.

fierspin.com also applies reasonable measures to control and limit money laundering risks, including allocating appropriate resources.

fierspin.com is committed to complying with high standards of Anti-Money Laundering (AML) in accordance with EU recommendations and requires management and staff to adhere to these standards to prevent the use of our services for money laundering purposes.

AML Program
fierspin.com's AML program is developed in accordance with:

EU: "Directive 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering."
EU: "Regulation 2015/847 on information accompanying transfers of funds."
EU: Various regulations establishing sanctions or restrictive measures against persons and embargoes on certain goods and technologies, including all dual-use goods.
Belgium: "Law of 18 September 2017 on the prevention of money laundering and the limitation of the use of cash."

Definition of Money Laundering
Money laundering is understood as:

The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from an act of participation in such activity, with the aim of concealing or disguising the illicit origin of the property or of assisting any person who is involved in such activity to evade the legal consequences of his actions;
The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
Participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counselling the commission of any of the actions mentioned above.
Money laundering is considered as such, even if the activities which generated the property to be laundered were carried out in the territory of another Member State or in a third country.

AML Organization for fierspin.com
In accordance with AML legislation, fierspin.com has appointed the "highest level" for the prevention of money laundering: overall management is responsible.

Furthermore, an AMLCO (AML Compliance Officer) is appointed, who is responsible for compliance with the AML policy and procedures within the system. The AMLCO is under the direct responsibility of the overall management.

AML Policy Changes and Implementation Requirements
Each major change to the AML policy of fierspin.com is subject to approval by the overall management and the AML Compliance Officer.

Two-Step Verification

First Step of Verification:
The first step of verification must be completed by each user and client for fund withdrawal. Regardless of the chosen payment method, payment amount, withdrawal amount, withdrawal method, and the user's/client's nationality, the first step of verification must be completed first. The first step of verification is a document that must be completed by the user/client themselves. The following information must be provided: first name, last name, date of birth, country of usual residence, gender, and full address.
Second Step of Verification:
The second step of verification is mandatory for each user who deposits or withdraws an amount exceeding $10,000 USD. Until the second step of verification is completed, the withdrawal, tipping, or deposit will be suspended. The second step of verification directs the user or client to a subpage where they must submit their identity document. The user/client must photograph their identity document, next to which is a piece of paper with a six-digit randomly generated number. Only an official identity document may be used for identity verification, although the list of acceptable documents may vary by country. Additionally, the user/client may be requested to provide their source of income. An electronic check is also conducted to ensure that the data provided in the first verification step matches the submitted document and the name on the identity document. If the electronic check fails or is not possible, the user/client is obliged to provide proof of their current place of residence. A state-issued registration certificate or equivalent document is required.

Customer Identification and Verification (KYC)
Formal identification of customers upon establishing business relations is an important element for both money laundering-related legislation and KYC policy. This identification is based on the following principles:

A copy of a passport, ID card, or driver's license with a handwritten note containing six randomly generated numbers. A second photograph with the user's/client's face is also required.
The user/client may hide any information except date of birth, nationality, gender, first name, last name, and photograph to protect their privacy.
All four corners of the identity document must be visible in a single image, and all details, except those mentioned above, must be clearly readable. If necessary, we may request all details. An employee may conduct additional checks if needed.

Proof of Address
Proof of address is conducted via two different electronic checks. If the electronic check fails, the user/client can provide proof manually: a utility bill issued in the last 3 months or an official document proving residence. All four corners of the document must be visible, and the text must be clear.

Source of Funds
If a player deposits more than €5,000, a Source of Wealth (SOW) verification process is initiated. Examples of sources of income: business ownership, employment, inheritance, investments, family. The account will be frozen until the source of funds is confirmed.

Risk Management
To manage various risks, fierspin.com classifies each country into three risk regions:

Region 1: Low risk
Region 2: Medium risk
Region 3: High risk – blocked
The list of high-risk regions is updated regularly.

Additional Measures
AI supervised by the AML officer monitors unusual behavior, and specialists conduct additional checks on transactions, sources of funds, and user activity. Withdrawals must be made via the same method used for the deposit.

Continuous Transaction Monitoring

First Line of Control: Cooperation with trusted payment service providers with effective AML policies.
Second Line of Control: Performing due diligence on all customer transactions, including an adapted three-step verification.
Third Line of Control: Manual checks of all suspicious and higher-risk users to prevent money laundering.

Suspicious Transaction Reporting
All atypical transactions are analyzed by the AML team. Based on the analysis, a decision is made on whether to send a report to the FIU and/or terminate the business relationship with the client.

Procedures and Data Storage
All AML rules, including KYC, are documented in operational manuals. Identification and transaction data are stored for at least ten years after the termination of the business relationship, in encrypted form.

Training and Audit
Employees undergo mandatory AML training and attend academic sessions. Internal audit conducts regular AML checks.

Data Security
All user/client data is securely protected and not shared with third parties without a legal basis. fierspin.com complies with the Data Protection Directive 95/46/EC.