Anti-Money Laundering Policy

SKINS24 is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our approach to compliance with the EU Anti-Money Laundering Directives (including the 6th Anti-Money Laundering Directive), and any other applicable AML regulations in the jurisdictions in which we operate.

All employees, contractors, and partners involved in SKINS24 operations are required to adhere to this policy.

We conduct regular risk assessments to identify and evaluate the money laundering and terrorist financing risks to which our business is exposed. Our risk assessment considers the nature of our services as a digital goods marketplace, the geographic locations of our users, the types of transactions processed, and the payment methods accepted.

The findings of our risk assessments inform our due diligence procedures, monitoring systems, and internal controls.

Standard Due Diligence: All users are identified through Steam OAuth authentication, which links their account to a verified Steam profile. Payment processing through EcommPay provides additional identity verification through card holder data and 3D Secure authentication.

Enhanced Due Diligence: For users whose transaction patterns exceed defined thresholds or who are identified as higher-risk, we may require additional identity verification. This may include government-issued photographic identification, proof of address, proof of source of funds, and enhanced ongoing monitoring.

Simplified Due Diligence: May be applied where the risk assessment indicates a demonstrably lower risk, in accordance with applicable regulations.

We monitor all transactions for suspicious activity using a combination of automated systems and manual review. Indicators that may trigger further investigation include: unusually large or frequent purchases that are inconsistent with normal user behaviour; rapid buying and selling patterns that may indicate layering; transactions involving jurisdictions subject to international sanctions; use of multiple payment methods or accounts by the same individual; and any patterns that deviate significantly from expected marketplace activity.

Flagged transactions are reviewed promptly, and appropriate action is taken which may include requesting additional information, delaying the transaction, or filing a suspicious activity report.

We screen users and transactions against applicable sanctions lists, including those maintained by the European Union, the United Nations, and the Office of Foreign Assets Control (OFAC). Users identified on any sanctions list are prohibited from using our platform, and their accounts will be suspended immediately.

Where we identify suspicious activity, we will file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit in accordance with applicable law. We are prohibited from informing the user that a report has been or may be filed (tipping off).

SKINS24 reserves the right to suspend or terminate accounts, freeze funds, and withhold items pending investigation and resolution of any suspected illegal activity.

We retain all customer identification records, transaction records, and internal reports for a minimum of 5 years after the end of the business relationship or the date of the transaction, whichever is later. These records are maintained securely and are available for inspection by competent authorities upon lawful request.

All relevant staff members receive AML training upon joining the company and on a recurring basis thereafter. Training covers the legal framework, our internal policies and procedures, how to recognise suspicious activity, and reporting obligations. Records of training are maintained.

This AML Policy is reviewed at least annually, or more frequently when there are material changes to our business, the regulatory environment, or our risk assessment. Updates are approved by senior management and communicated to all relevant personnel.