Beat.gg AML Policy

1. Introduction

Beat.gg is operated by 3-102-952292 SRL, ID: 3-102-952292, with its registered address at San Pedro, Barrio Dent, del Centro Cultural Costarricense Norteamericano, doscientos metros al norte y cincuenta al este, Edificio Ofident, Oficina Numero Tres.

Beat.gg is committed to the prevention of money laundering and the financing of terrorism. This Anti-Money Laundering (AML) Policy outlines our approach to ensure compliance with applicable laws, including the EU’s Sixth Anti-Money Laundering Directive (6AMLD), FATF Recommendations, and the General Data Protection Regulation (GDPR).

2. Objective of the Policy

To safeguard our platform, customers, and financial systems, Beat.gg has implemented a three-step account verification process and continuous transaction monitoring. Our objective is to ensure that user identities are verified, financial activities are legitimate, and risks related to money laundering are mitigated.

3. Legal Framework

Beat.gg aligns its AML measures with:

• Directive (EU) 2015/849, as amended by Directive (EU) 2018/843 and Directive (EU) 2018/1673 (6AMLD).
• Regulation (EU) 2015/847 on information accompanying transfers of funds.
• GDPR (Regulation (EU) 2016/679).
• Anjouan AML legislation.
• Relevant FATF Recommendations.

4. Definition of Money Laundering

Money laundering involves:

• Concealing the origin of criminal proceeds.
• Converting or transferring illicit assets to disguise their origin.
• Acquiring or using criminally obtained property knowingly.
• Aiding or facilitating any of the above actions.

Money laundering is illegal even when the predicate offense occurs in another jurisdiction.

5. Governance Structure

• General Management of 3-102-952292 SRL holds ultimate responsibility for AML compliance.
• An Anti-Money Laundering Compliance Officer (AMLCO) oversees implementation, reporting, and risk assessments.

6. Customer Due Diligence (KYC)

Beat.gg enforces identity verification at account creation and during certain transactions.

Required Documents:

• Government-issued ID (passport, ID card, or driver's license) with:
  • A selfie holding the ID and a handwritten note with 6 randomly generated numbers.
  • Visible corners of the document.
  • Only essential fields (name, DOB, nationality, gender, photo) required unless further data is necessary.
• Proof of Address:
  • Verified electronically via two databases. If failed, a manual document such as a utility bill, government letter, or bank statement dated within 3 months is required.
• Source of Funds:
  • May include employment documents, business ownership proof, inheritance, or investment records.

7. Transaction Monitoring

Beat.gg employs a three-tiered transaction monitoring system:

• 1. Automated Monitoring: AI-driven systems detect irregularities such as:
  • Repeated deposits/withdrawals without gameplay.
  • Use of different payment methods.
  • Account behavior or geographic changes.
• 2. Employee Review: Trained personnel review AI alerts and perform manual verification.
• 3. Manual Audits: Higher-risk users and suspicious accounts are audited manually.

All suspicious transactions are escalated to the AMLCO.

8. Risk-Based Approach (EWRA)

Beat.gg conducts an annual Enterprise-Wide Risk Assessment (EWRA), analyzing:

• Products/services offered.
• Transaction types.
• User profiles and geographies.
• Delivery channels and emerging risks.

The AMLCO uses EWRA outcomes to adjust AML policies.

9. Reporting Suspicious Activity

All employees must report suspicious activity to the AML team. The AMLCO:

• Reviews the report.
• Files a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit (FIU) if necessary.
• May terminate user accounts based on findings.

10. Record Keeping

In line with legal requirements:

• KYC documentation is retained for 10 years after account closure.
• Transaction records are stored securely (offline and encrypted) for 10 years.

11. Staff Training

Beat.gg ensures:

• All employees undergo mandatory AML training annually.
• New hires receive academic AML instruction tailored to their role.
• Training is updated in line with regulatory changes.

12. Data Protection

Beat.gg complies with the GDPR. User data:

• Is securely stored.
• Is not shared unless legally required (e.g., AML investigations).

13. Contact & Complaints

For AML or KYC-related inquiries: Email: support@beat.gg

14. Version Control

Version: 1.2

Last Reviewed: October 28, 2025

Next Scheduled Review: October 2026