Anti-Money Laundering Policy

SKINS24 is dedicated to the prevention of money laundering, terrorist financing, and other forms of financial crime. This Anti-Money Laundering (AML) Policy sets out our approach to compliance with the EU Anti-Money Laundering Directives (including the 6th Anti-Money Laundering Directive) and any other relevant AML legislation applicable in the jurisdictions where we conduct business.

All employees, contractors, and partners engaged in SKINS24 operations are obligated to comply with this policy.

We perform periodic risk assessments to identify and evaluate money laundering and terrorist financing risks that may affect our business. These assessments take into account the nature of our services as a digital goods marketplace, the geographic distribution of our user base, the types of transactions we process, and the payment methods we support.

The outcomes of our risk assessments guide our due diligence procedures, monitoring frameworks, and internal controls.

Standard Due Diligence: Every user is identified through Steam OAuth authentication, which links their account to a verified Steam profile. Our payment processor supplies additional identity verification via cardholder information and 3D Secure authentication.

Enhanced Due Diligence: Users whose transaction activity exceeds established thresholds or who are classified as higher-risk may be asked to provide supplementary identification. This may include a government-issued photo ID, proof of residential address, evidence of the source of funds, and heightened ongoing monitoring.

Simplified Due Diligence: May be applied in situations where the risk assessment demonstrates a clearly lower level of risk, in keeping with applicable regulations.

All transactions are monitored for suspicious behaviour using a blend of automated systems and manual review. Indicators that may trigger further scrutiny include: unusually large or frequent purchases inconsistent with typical user activity; rapid buy-and-sell cycles that may suggest layering; transactions involving jurisdictions under international sanctions; use of multiple payment instruments or accounts by a single individual; and any patterns that materially deviate from expected marketplace behaviour.

Flagged transactions are evaluated promptly, and appropriate measures are taken — which may include requesting additional documentation, placing the transaction on hold, or filing a suspicious activity report.

Users and transactions are screened against relevant sanctions lists, including those published by the European Union, the United Nations, and the Office of Foreign Assets Control (OFAC). Any user appearing on a sanctions list is immediately barred from using our platform, and their account is suspended without delay.

When suspicious activity is identified, we will submit a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) to the appropriate Financial Intelligence Unit as required by law. We are legally prohibited from notifying the user that a report has been or may be submitted (tipping off).

SKINS24 retains the right to freeze accounts, withhold funds, and hold back items pending the investigation and resolution of any activity suspected to be unlawful.

All customer identification records, transaction logs, and internal reports are retained for a minimum of 5 years following the end of the business relationship or the date of the transaction, whichever is later. These records are stored securely and are available for review by competent authorities upon lawful request.

All relevant team members undergo AML training when they join the company and at regular intervals thereafter. The training programme covers the legal and regulatory framework, our internal policies and procedures, the identification of suspicious activity, and reporting obligations. Training records are documented and retained.

This AML Policy is reviewed no less than once per year, or more often when warranted by significant changes to our business, the regulatory landscape, or our risk profile. Any revisions are approved by senior management and communicated to all relevant personnel.