AML / KYC Policy

Effective Date: 9.09.2024

Introduction

Poliada World UAB is firmly committed to the highest standards of anti-money laundering (AML) and know your customer (KYC) compliance, in line with the laws of the Republic of Lithuania, European Union (EU) regulations, and international best practices. This policy outlines the measures we take to prevent illicit activities such as money laundering, terrorist financing, and other financial crimes.

This AML/KYC Policy applies exclusively to investors in Poliada World UAB’s game with a crypto economy, encompassing both the Initial Coin Offering (ICO) and any future investment opportunities. While regular players of the game are not subject to AML/KYC requirements, we enforce strict compliance measures for all current and future investors to ensure the integrity of our platform. Poliada World UAB utilizes advanced tools, including Chainalysis, for transaction verification and monitoring across all investments, ensuring comprehensive compliance and security.

Section 1: Scope and Purpose

1.1 Scope

This policy applies to all individuals investing in Poliada World UAB's game with a crypto economy. It covers:

Investor Identification and Verification: Implementing procedures to verify the identity of all investors, in compliance with the Lithuanian Law on the Prevention of Money Laundering and Terrorist Financing.
Risk-Based Management: Managing risks associated with investors from jurisdictions identified by the Financial Action Task Force (FATF) as high-risk or under increased monitoring.
Source of Funds (SOF) Verification: Verifying the legitimacy of funds for investments equal to or exceeding €15,000, in accordance with EU AML Directives and Lithuanian legislation.
Transaction Monitoring: Utilizing Chainalysis and other compliance tools to screen and monitor all investments, regardless of amount, to assess and manage risk effectively.

1.2 Purpose

The purpose of this policy is to:

Ensure Legal Compliance: Adhere to Lithuanian laws, including the Law on the Prevention of Money Laundering and Terrorist Financing, EU AML Directives (such as the 5th and 6th AML Directives), and relevant international regulations.
Prevent Illicit Activities: Detect and prevent money laundering, terrorist financing, fraud, and other financial crimes.
Mitigate Risks: Identify, assess, and mitigate risks associated with high-risk jurisdictions, large transactions, and suspicious activities.
Maintain Transparency and Accountability: Ensure transparency in all investment processes, maintaining accurate records and reporting as required by law.
Protect Stakeholders: Safeguard the interests of Poliada World UAB, its investors, and the broader financial system by implementing robust AML/KYC measures.

Section 2: Country-Based Restrictions and Risk Management for Investors

2.1 Prohibited Jurisdictions (High-Risk and Sanctioned Countries)

Poliada World UAB strictly prohibits investments from individuals located in countries or territories that are subject to sanctions or identified as high-risk by the Financial Action Task Force (FATF), the European Union (EU), the United Nations (UN), and the Republic of Lithuania.

Prohibited Countries and Territories include but are not limited to:

Sanctioned Countries:

North Korea (Democratic People's Republic of Korea)
Iran
Syria
Crimea Region of Ukraine

High-Risk Jurisdictions:

Countries identified by the FATF as high-risk with significant strategic deficiencies in their AML/CFT (Countering the Financing of Terrorism) regimes.

Rationale for Prohibition:

Legal Compliance: Adhering to international sanctions and Lithuanian laws to prevent financial transactions that could support illicit activities.
Risk Mitigation: Reducing the risk of money laundering, terrorist financing, and other financial crimes by avoiding high-risk jurisdictions.

2.2 Restricted Jurisdictions (Jurisdictions under Increased Monitoring)

Investors from jurisdictions identified by the FATF as having strategic AML/CFT deficiencies but committed to addressing them—often referred to as "grey list" countries—are subject to Enhanced Due Diligence (EDD) measures.

Restricted Countries and Territories include but are not limited to:

Albania
Barbados
Burkina Faso
Cambodia
Cayman Islands
Haiti
Jamaica
Jordan
Mali
Morocco
Myanmar
Nicaragua
Pakistan
Panama
Philippines
Senegal
South Sudan
Syria
Uganda
Yemen
Zimbabwe

Policy for Restricted Jurisdictions:

Enhanced Due Diligence (EDD): Investors from these jurisdictions must undergo EDD procedures, including additional identity verification and Source of Funds (SOF) verification, regardless of the investment amount.
Continuous Monitoring: All transactions from these investors will be closely monitored using Chainalysis and other compliance tools.
Management Approval: Investments from these jurisdictions require approval from senior management.

2.3 Risk Assessment and Management

Poliada World UAB adopts a risk-based approach in compliance with Lithuanian law and EU AML Directives. This involves:

Customer Risk Profiling:

Low Risk: Investors from EU member states with transparent AML/CFT regimes.
Medium Risk: Investors from countries with adequate but not robust AML/CFT measures.
High Risk: Investors from restricted jurisdictions or those involved in high-risk activities.

Transaction Monitoring:

Automated Monitoring: Utilizing Chainalysis to monitor all transactions for suspicious activities.
Manual Review: Compliance officers review flagged transactions for potential risks.

Ongoing Due Diligence:

Regularly updating investor information and risk assessments.
Monitoring for changes in investor status, such as becoming a Politically Exposed Person (PEP).

2.4 High-Risk Activities and Industries

Investments from individuals involved in certain high-risk activities or industries may be subject to additional scrutiny or may be prohibited. These include:

Arms and Weapons Trade
Precious Metals and Stones Dealers
Money Service Businesses (MSBs)
Shell Companies

Policy for High-Risk Activities:

Enhanced Due Diligence: Mandatory EDD procedures, including detailed SOF and Source of Wealth (SOW) verifications.
Senior Management Approval: Required for accepting investments from these sectors.
Ongoing Monitoring: Increased frequency of transaction monitoring and reviews.

2.5 Politically Exposed Persons (PEPs)

Investors identified as Politically Exposed Persons (PEPs), or their immediate family members and close associates, are subject to EDD measures.

Definition of PEPs:

Individuals who are or have been entrusted with prominent public functions, such as:

Heads of State or Government
Senior Politicians
Senior Government, Judicial, or Military Officials
Senior Executives of State-Owned Corporations
Important Political Party Officials

EDD Measures for PEPs:

Enhanced Identity Verification: Verification of identity through multiple reliable and independent sources.
SOF and SOW Verification: Detailed documentation proving the legitimacy of funds and wealth.
Senior Management Approval: Required before establishing a business relationship.
Enhanced Monitoring: Continuous monitoring of transactions and activities.

2.6 Sanctions and Watchlists Screening

Poliada World UAB screens all investors against relevant sanctions lists and watchlists, including:

EU Consolidated Sanctions List
UN Consolidated Sanctions List
OFAC (Office of Foreign Assets Control) Sanctions List
Lithuanian National Sanctions Lists
Other Relevant International Sanctions Lists

Policy for Matches on Sanctions Lists:

Positive Match Protocol:

Immediate Freeze: Suspend the transaction or investment process.
Internal Review: Our compliance team conducts a detailed review of the match.
Reporting: We report the incident to the Financial Crime Investigation Service (FCIS) in Lithuania and other relevant authorities.
No Notification to Investor: As per legal requirements, you will not be informed about the investigation to avoid tipping off.

2.7 Actions upon Identification of High-Risk or Prohibited Investors

Refusal of Service: Poliada World UAB reserves the right to refuse service to any investor who:

Fails to meet AML/KYC requirements.
Is identified as prohibited under this policy.
Provides false or misleading information.

Termination of Business Relationship: Existing relationships will be terminated if the investor is later found to be high-risk or prohibited.

Reporting Obligations:

Suspicious Activity Reports (SARs): Filed with the FCIS when suspicious activities are detected.
Cooperation with Authorities: Full cooperation with law enforcement and regulatory bodies during investigations.

2.8 Record-Keeping

Documentation: We maintain records of all checks conducted, decisions made, and actions taken regarding high-risk and prohibited investors.
Retention Period: Records are retained for at least eight years after the end of the business relationship or the date of the occasional transaction, in compliance with Lithuanian law.

Section 3: Investor Due Diligence (IDD)

Poliada World UAB is dedicated to ensuring that all private investors comply with our AML/KYC standards. By investing with us, you agree to the following procedures designed to verify your identity and assess potential risks associated with your investment.

3.1 Standard Due Diligence Procedures

We implement thorough Investor Due Diligence (IDD) procedures to verify your identity and assess potential risks, in compliance with the Lithuanian Law on the Prevention of Money Laundering and Terrorist Financing and relevant EU AML Directives.

3.1.1 Identification and Verification of Private Investors

As part of our commitment to AML/KYC compliance, we require the following information and documentation from all private investors:

Required Information:

Full Name
Date and Place of Birth
Nationality
Residential Address
Contact Details (phone number and email address)

Required Documentation:

Proof of Identity: Valid government-issued photo identification (e.g., passport, national ID card)

3.1.2 Understanding Your Investor Profile

To establish a clear understanding of your background and the nature of your investment, Poliada World UAB:

Assesses the Purpose and Intended Nature of the Investment: Gathers information on your investment objectives and expected investment activity.

Evaluates the Source of Funds and Wealth (if applicable): Requires information or documentation to verify that the funds used for investment are derived from legitimate sources.

3.1.3 Verification Methods

We employ the following methods to verify the authenticity of the information and documentation you provide:

Document Verification: Examination of original identification documents or certified copies to confirm authenticity.

Electronic Verification: Utilization of reliable and secure electronic verification systems where appropriate.

3.2 Enhanced Due Diligence (EDD)

In situations where there is a higher risk of money laundering or terrorist financing, we apply Enhanced Due Diligence (EDD) measures. This includes, but is not limited to:

Investors from High-Risk or Restricted Jurisdictions: As defined in Section 2 of this policy.

Politically Exposed Persons (PEPs): Individuals who hold or have held prominent public positions, their immediate family members, or close associates.

Unusual or Large Transactions: Transactions that are significantly larger than usual or not consistent with your known profile.

3.2.1 EDD Measures for High-Risk Investors

For high-risk investors, we undertake the following additional measures:

Additional Identification Information: Collecting further identification documents or information as necessary to conclusively establish your identity.

Source of Funds Verification: Obtaining detailed evidence of the origin of your funds, such as bank statements, employment income records, or documentation of asset sales.

Senior Management Approval: Requiring approval from senior management before establishing or continuing a business relationship.

Enhanced Monitoring: Applying increased scrutiny to your transactions and activities, including more frequent reviews.

3.3 Ongoing Monitoring and Due Diligence

We continuously monitor all investor relationships to ensure that transactions are consistent with your profile and to detect any unusual or suspicious activity.

Transaction Monitoring: Continuously monitoring transactions using tools like Chainalysis to identify and assess any anomalies or red flags.

Periodic Reviews: Regularly updating your information and risk assessments, especially when significant changes occur in your circumstances.

3.4 Record-Keeping and Data Protection

We are committed to maintaining the highest standards of data protection and record-keeping.

Documentation Retention:

Data Security:

Implementing robust security measures to protect your personal data against unauthorized access, alteration, or disclosure.

Adhering to the General Data Protection Regulation (GDPR) and Lithuanian data protection laws.
You have rights regarding your personal data, including access and correction.

3.5 Refusal or Termination of Business Relationship

Poliada World UAB reserves the right to refuse to establish or terminate a business relationship if:

Non-Compliance with IDD Requirements: You fail or refuse to provide the required identification information or documentation.

False or Misleading Information: You provide information that is false, misleading, or incomplete.

High-Risk Profile: You are identified as high-risk or are from a prohibited jurisdiction under this policy.

Suspicious Activities: Suspicious activities are detected, and satisfactory explanations are not provided.

3.6 Reporting Obligations

Suspicious Activity Reporting (SAR): Any suspicious activities identified during due diligence or ongoing monitoring are promptly reported to the Financial Crime Investigation Service (FCIS) in Lithuania.

Confidentiality and Legal Compliance: We are required to maintain confidentiality and comply with legal obligations regarding the non-disclosure of SARs to you or any unauthorized party.

Section 4: Source of Funds (SOF) Verification for High-Value Investments

Poliada World UAB is committed to ensuring that all funds invested in our game with a crypto economy are derived from legitimate sources. To comply with Lithuanian law and EU AML Directives, we require additional verification for investments equal to or exceeding €15,000.

4.1 SOF Verification Requirements

If your total investment equals or exceeds €15,000, whether in a single transaction or through multiple transactions that appear to be linked, you will be required to provide evidence of the source of your funds.

4.1.1 Acceptable Documentation

To verify the legitimacy of your funds, we may request one or more of the following documents:

Bank Statements: Recent statements showing your name, account number, and transaction history.
Payslips or Employment Income Records: Documents verifying your regular income from employment.
Tax Returns: Official tax documents indicating your income.
Sale of Assets: Documentation confirming the sale of property, investments, or other assets.
Inheritance Documents: Legal documents proving inheritance of funds.
Gift Letters: If funds were received as a gift, a signed letter from the donor explaining the nature of the gift and the relationship to you.
Other Relevant Financial Documents: Any other documents that can confirm the legitimate origin of your funds.

4.1.2 Submission Process

Secure Upload: You will be provided with a secure method to upload your documents to ensure confidentiality and data protection.
Timely Provision: Please provide the requested documents within the specified timeframe to avoid delays in processing your investment.

4.2 Purpose of SOF Verification

The SOF verification process helps us to:

Comply with Legal Obligations: Fulfill our legal obligations under Lithuanian law and EU AML Directives to prevent money laundering and terrorist financing.
Ensure Integrity of Investments: Protect the integrity of our platform by ensuring all funds are sourced legitimately.
Promote Transparency: Maintain a transparent investment environment for the benefit of all stakeholders.

4.3 Confidentiality and Data Protection

We understand the sensitive nature of the information you provide. All documents and information submitted for SOF verification are handled with the highest level of confidentiality and in compliance with the General Data Protection Regulation (GDPR) and Lithuanian data protection laws.

Data Security Measures: We implement robust security protocols to protect your data from unauthorized access or disclosure.
Limited Access: Only authorized personnel involved in compliance and verification processes will have access to your documents.

4.4 Failure to Provide SOF Documentation

If you fail to provide the required SOF documentation:

Investment Delay: Processing of your investment may be delayed until the necessary documents are provided and verified.
Refusal of Service: We reserve the right to refuse or terminate the business relationship if adequate SOF documentation is not provided.

4.5 Ongoing Monitoring

Even after initial SOF verification, we may request additional information or documentation if:

Transaction Patterns Change: Significant changes occur in your investment patterns or transaction behaviors.
Regulatory Changes: Updates in laws or regulations require additional verification measures.
Suspicious Activity Detected: Unusual or suspicious activity is identified during ongoing monitoring.

Section 5: Transaction Monitoring and Suspicious Activity Reporting (SAR)

Poliada World UAB is committed to ongoing vigilance in monitoring investor transactions to prevent and detect any suspicious activities related to money laundering, terrorist financing, or other financial crimes. We utilize advanced tools and adhere to strict protocols to ensure compliance with Lithuanian law and EU AML Directives.

5.1 Transaction Monitoring

We employ a combination of automated systems and manual reviews to monitor all investor transactions:

Automated Monitoring with Chainalysis:

Real-Time Analysis: We use Chainalysis, a leading blockchain analysis tool, to monitor cryptocurrency transactions in real-time.
Risk Scoring: Transactions are assessed for risk based on patterns, amounts, and connections to known illicit activities.
Alert Generation: The system generates alerts for transactions that meet certain risk criteria.

5.2 Identification of Suspicious Activities

Transactions or activities that may be considered suspicious include, but are not limited to:

Unusual Transaction Patterns:

Large or frequent transactions that are inconsistent with your known investment profile.
Sudden changes in transaction behavior without a reasonable explanation.

Structured Transactions:

Multiple smaller transactions made to avoid reporting thresholds or detection.

Connections to High-Risk Sources:

Transactions involving addresses or entities linked to illicit activities, sanctioned parties, or high-risk jurisdictions.

Refusal to Provide Information:

Reluctance or refusal to provide required identification or SOF documentation.

5.3 Reporting Suspicious Activities

In compliance with legal obligations, Poliada World UAB will take the following actions upon identifying suspicious activities:

Internal Escalation:

The compliance team escalates the matter to senior management for review and decision-making.

Suspicious Activity Reports (SARs):

Filing with Authorities: We promptly file a SAR with the Financial Crime Investigation Service (FCIS) in Lithuania, providing all necessary details.
Confidentiality: By law, we are prohibited from disclosing to you or any third party that a SAR has been filed or that an investigation may be underway.

Account Actions:

Transaction Freezing: We may suspend or restrict your account and transactions pending the outcome of the investigation.
Termination of Relationship: If required, we may terminate the business relationship in accordance with Section 3.5 of this policy.

5.4 Legal Obligations and Compliance

Our transaction monitoring and reporting practices are conducted in strict adherence to:

Lithuanian Law:

Law on the Prevention of Money Laundering and Terrorist Financing.
Relevant regulations and guidelines issued by Lithuanian authorities.

EU AML Directives:

Compliance with the 5th and 6th EU AML Directives and any subsequent amendments.

5.5 Your Responsibilities

As an investor, you are expected to:

Provide Accurate Information: Ensure all information and documentation you provide is truthful and up-to-date.

Report Changes: Notify us promptly of any changes to your personal information or circumstances that may affect your investor profile.

Comply with Requests: Cooperate with any requests for additional information or documentation related to compliance matters.

5.6 Data Protection and Confidentiality

We handle all transaction data and reports with the utmost confidentiality:

Secure Handling: All data is stored securely, with access limited to authorized personnel.

Compliance with GDPR: Adhering to data protection regulations, ensuring your rights are respected.

Section 6: Data Protection and Privacy

Poliada World UAB is committed to safeguarding the personal data and privacy of our investors. We adhere strictly to the General Data Protection Regulation (GDPR) and Lithuanian data protection laws to ensure that your personal information is handled responsibly and securely.

6.1 Data Collection and Use

We collect and process personal data necessary for AML/KYC compliance and to provide our services effectively.

Types of Data Collected:

Identification Information: Name, date of birth, nationality.
Contact Details: Residential address, email address, phone number.
Financial Information: Source of funds documentation, transaction history.
Verification Documents: Copies of identification documents and proof of address.
Transactional Data: Details of investments and related activities.

Purpose of Data Processing:

Legal Compliance: To fulfill our obligations under AML/KYC regulations.
Service Provision: To facilitate your investments and manage our relationship.
Security Measures: To monitor and prevent fraudulent or suspicious activities.
Communication: To inform you about important updates, changes to policies, or other relevant information.

6.2 Data Security Measures

We implement robust security protocols to protect your personal data from unauthorized access, alteration, disclosure, or destruction.

Technical Measures:

Encryption: Data is encrypted both in transit and at rest.
Secure Servers: Hosting on secure servers with firewall protection.
Access Controls: Restricted access to personal data on a need-to-know basis.
Regular Audits: Periodic security assessments and penetration testing.

Organizational Measures:

Staff Training: Employees are trained on data protection and confidentiality.
Policies and Procedures: Clear guidelines on data handling and incident response.
Third-Party Agreements: Ensuring that any third parties processing data on our behalf comply with GDPR.

6.3 Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements.

Retention Period: AML/KYC records are retained for at least eight years after the end of the business relationship, as required by Lithuanian law.

Deletion of Data: After the retention period, personal data is securely deleted or anonymized, unless otherwise required by law.

As an investor, you have certain rights regarding your personal data:

Right to Access: You can request a copy of the personal data we hold about you.
Right to Rectification: You can request correction of inaccurate or incomplete data.
Right to Erasure: You can request deletion of your personal data under certain circumstances.
Right to Restrict Processing: You can request that we limit the processing of your data under specific conditions.
Right to Data Portability: You can request to receive your data in a structured, commonly used, and machine-readable format.
Right to Object: You can object to the processing of your personal data for certain purposes.

6.5 Exercising Your Rights

To exercise any of your rights, please contact our Data Protection Officer (DPO):

Email: [email protected]
Postal Address:
Poliada World UAB
Naugarduko g. 68-3
Vilnius
Lithuania

We will respond to your request within one month, in accordance with GDPR requirements.

We do not sell or rent your personal data to third parties. However, we may share your data under the following circumstances:

Service Providers: With third-party providers who assist us in operating our business (e.g., Chainalysis for transaction monitoring), provided they adhere to data protection obligations.

Legal Obligations: When required by law, we may disclose your personal data to regulatory authorities, law enforcement agencies, or courts.

Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred, subject to confidentiality agreements and data protection laws.

6.7 International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). In such cases, we ensure that appropriate safeguards are in place, such as:

Standard Contractual Clauses: Utilizing contractual agreements approved by the European Commission.
Adequacy Decisions: Transferring data to countries recognized by the European Commission as providing an adequate level of data protection.

6.8 Cookies and Website Data

Our website may use cookies and similar technologies to enhance user experience:

Types of Cookies:

Essential Cookies: Necessary for website functionality.
Analytical Cookies: Help us understand how users interact with our site.
Preference Cookies: Remember your preferences and settings.

Managing Cookies:

You can manage your cookie preferences through your browser settings or our website's cookie management tool.

For more details, please refer to our Cookie Policy.

Section 7: Policy Updates and Contact Information

7.1 Policy Review and Updates

Poliada World UAB is committed to maintaining the accuracy and effectiveness of this AML/KYC Policy. We regularly review and update our policies to reflect:

Changes in Laws and Regulations: Adapting to amendments in Lithuanian laws, EU directives, and international AML/CFT standards.

Evolving Industry Practices: Incorporating best practices and technological advancements in compliance and security.

Feedback and Compliance Findings: Considering feedback from investors and findings from internal audits or regulatory reviews.

7.1.1 Notification of Changes

Investor Communication: Significant updates to the policy will be communicated to you via email or through notices on our website.

Effective Date: The effective date of the updated policy will be clearly indicated at the beginning of the document.

Continued Compliance: By continuing to invest with us after changes take effect, you agree to be bound by the updated policy.

7.2 Investor Acknowledgment and Agreement

By investing with Poliada World UAB, you acknowledge and agree to the terms outlined in this AML/KYC Policy:

Acceptance During Investment Process: You will be required to read and accept this policy as part of the investment onboarding procedure.

Obligation to Comply: You agree to provide accurate information and comply with all requests necessary for AML/KYC compliance.

Awareness of Legal Implications: You understand that non-compliance may result in the suspension or termination of your investment and potential legal actions.

7.3 Contact Information

If you have any questions, concerns, or require further information about this AML/KYC Policy or related matters, please contact us:

Compliance Department:

Email: [email protected]
Postal Address:
Poliada World UAB
Naugarduko g. 68-3
Vilnius
Lithuania

Data Protection Officer (DPO):

Email: [email protected]

7.4 Complaint and Dispute Resolution

We are dedicated to addressing any complaints or disputes promptly and fairly:

Filing a Complaint: Please submit a detailed description of your issue to our Compliance Department via email or postal mail.

Acknowledgment and Response: We will acknowledge receipt of your complaint within five business days and aim to provide a substantive response within one month.

Further Actions: If you are not satisfied with our response, you may refer your complaint to the appropriate regulatory authority in Lithuania.

7.5 Governing Law and Jurisdiction

This AML/KYC Policy is governed by and construed in accordance with the laws of the Republic of Lithuania. Any disputes arising from or in connection with this policy shall be subject to the exclusive jurisdiction of the courts of Lithuania.