1. Policy Statement
MPlay Games is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML Policy establishes procedures to detect, prevent, and report suspicious activities in compliance with international regulations.
2. Regulatory Compliance
This policy complies with:
- Curaรงao Gaming Control Board (GCB) requirements
- Financial Action Task Force (FATF) recommendations
- EU Anti-Money Laundering Directives
- International best practices for online gaming
3. Know Your Customer (KYC)
Verification Tiers
| Level | Requirements | Limits |
|---|---|---|
| Level 0 | Email + Age Confirmation | Play only, no withdrawals |
| Level 1 | Government ID + Selfie | Up to $1,000 lifetime |
| Level 2 | Proof of Address + Enhanced Verification | Unlimited |
Required Documents
- Identity Verification โ Government-issued photo ID (passport, driver's license, national ID)
- Liveness Check โ Selfie holding ID or video verification
- Address Verification โ Utility bill or bank statement (dated within 3 months)
- Source of Funds โ Required for high-value transactions exceeding $10,000
4. Transaction Monitoring
Automated Detection
We employ real-time monitoring for:
- Unusual deposit patterns
- Rapid deposit-withdrawal cycles with minimal gameplay
- Transactions to/from high-risk cryptocurrency addresses
- Velocity anomalies (unusual transaction frequency)
Red Flag Indicators
| Indicator | Description |
|---|---|
| Structuring | Multiple transactions just below reporting thresholds |
| Rapid Cycling | Depositing and withdrawing with minimal play |
| Third-Party Payments | Deposits from wallets not belonging to the user |
| Mixer/Tumbler Usage | Transactions linked to cryptocurrency mixers |
| Geographic Mismatch | IP location inconsistent with registration country |
5. Cryptocurrency Compliance
We utilize blockchain analytics tools to:
- Screen wallet addresses against sanctions lists
- Identify funds from mixers, tumblers, or darknet markets
- Track transaction origins and assess risk scores
- Comply with the Travel Rule for high-value transfers
High-Risk Wallet Actions
| Category | Action Taken |
|---|---|
| Sanctioned Addresses | Transaction blocked, SAR filed |
| Known Mixer Output | Enhanced scrutiny, possible rejection |
| Darknet Market Linked | Transaction blocked, investigation |
6. Sanctions Compliance
All users are screened against:
- OFAC SDN List (U.S. Treasury)
- EU Sanctions List
- UN Consolidated List
- FATF Blacklisted Countries
Blocked Jurisdictions
Users from the following jurisdictions are prohibited:
- United States
- North Korea
- Iran
- Cuba
- Syria
- Crimea Region
7. Reporting Obligations
We file Suspicious Activity Reports (SARs) with relevant authorities when:
- Reasonable suspicion of money laundering exists
- Transactions cannot be explained by legitimate gaming activity
- Required by regulatory guidelines
All transaction records are retained for 7 years.
8. Contact
To report suspicious activity or for compliance inquiries:
Compliance Officer
Email: compliance@mplay.in