PCGAME INC AML (Anti-Money Laundering) Policy
1. General
This company (the "Company") is committed to establishing and maintaining an effective Anti-Money Laundering (AML) program, in accordance with applicable laws and regulations, designed to detect and prevent money laundering activities related to the sale of digital goods.
2. Customer Identification and Verification
The Company will take reasonable steps to identify and verify the identity of each customer prior to entering a business relationship. This includes collecting customer information such as name, address, and contact information. The Company may also request additional information and documents as necessary to confirm the customer's identity.
3. Risk Assessment
The Company will conduct a risk assessment to determine the level of risk associated with each customer. This includes assessing the customer's country of origin, the nature of the digital goods being purchased, and the customer’s intended use of the digital goods.
4. Transaction Monitoring
The Company will monitor customer transactions to identify suspicious activities. This includes monitoring for large or unusual transactions, transactions with no apparent economic purpose, and transactions with jurisdiction associated with high risk of money laundering.
5. Limiting Spending
The company will maintain "hard-coded" spending limits for each customer account, not allowing the consumer to exceed transaction thresholds that could be associated with money laundering. Maintaining account spending limits below $10,000 per month, with the normal monthly volume limit not exceeding $2,500 per month.
6. Restricting user access to one account
To assure spending limits have integrity our company deploys technology to monitor a user throughout our network, then restricting that user to the use of only one customer account. If a customer is found to have bypassed these restrictions and has been found to have created a second account, this account will be immediately terminated. Enforcing the restriction of one account per one customer.
7. Reporting
The Company will report any suspicious activities to applicable authorities as required.
1. Reporting Obligations (SAR, CTR, STR, LCTR)
Suspicious Activity Reporting (SAR/STR):PC Game Supply shall report any transaction or activity that appears to involve money laundering or terrorist financing to the appropriate regulatory authority, including:
- FinCEN (U.S.): Submission of SARs for transactions involving $5,000 or more that appear suspicious.
- FINTRAC (Canada): Filing of STRs for suspected criminal financial activity.
- EU Jurisdictions: Suspicious transaction reports will be submitted to the relevant Financial Intelligence Unit (FIU) in accordance with AMLD regulations.
Currency and Large Transaction Reporting (CTR/LCTR):
Where applicable, PC Game Supply will comply with obligations to report:
- CTRs (U.S.) for cash transactions exceeding $10,000
- LCTRs (Canada) for cash transactions of CAD $10,000 or more
- Record and report thresholds in EU jurisdictions as defined by national implementation of AMLD
🗂 2. Recordkeeping Requirements
PC Game Supply will retain records to demonstrate compliance with AML laws for the minimum periods specified by each jurisdiction:
| Document Type | U.S. (BSA) | Canada (FINTRAC) | EU (AMLD5+) |
|---|---|---|---|
| Customer ID & KYC | 5 years | 5 years | 5 years |
| Transaction Records | 5 years | 5 years | 5 years |
| SAR/STR Filing Logs | 5 years | 5 years | Varies |
All records will be securely stored and made available to regulatory authorities upon lawful request.
🛂 3. Enhanced Due Diligence (EDD) and Politically Exposed Persons (PEPs)
In accordance with FATF recommendations and AMLD5+:
- Enhanced Due Diligence (EDD) will be applied to customers who present a higher risk, including those from high-risk jurisdictions or those engaged in high-volume transactions.
🧪 4. Independent Testing and Audit
- The AML program is independently tested at least annually by an internal with no operational AML duties.
- Findings from the audit will be reported to executive management and the board of directors, with documented remediation timelines.
🏛 5. Regulatory Cooperation and Jurisdictional Compliance
PC Game Supply will:
- Cooperate with law enforcement and financial intelligence units (FIUs) in all relevant jurisdictions.
- Maintain a clear understanding of local AML obligations in countries of operation.
- Ensure the policy is periodically updated to reflect regulatory changes across the U.S., Canada, EU, and any other applicable jurisdictions.
✅ 6. AML Officer Designation
An AML Compliance Officer will be designated to oversee the program, including:
- Ensuring filing of SARs/STRs and compliance reports
- Maintaining the training schedule
- Coordinating with auditors and regulatory authorities
- Updating internal procedures in response to legislative or regulatory changes