Compliance

ANTI-MONEY LAUNDERING (AML) AND ANTI-FRAUD COMPLIANCE POLICY

Company Name: SkillSphere Game Inc.

1. INTRODUCTION AND PURPOSE

SkillSphere Game Inc. ("the Company") is committed to the highest standards of integrity and compliance with U.S. laws. This policy establishes the framework for preventing, detecting, and reporting money laundering, terrorist financing, and fraudulent activities within our gaming platforms.

The Company complies with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and regulations overseen by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).

2. ANTI-MONEY LAUNDERING (AML) FRAMEWORK

2.1 Customer Identification Program (KYC/CIP)

While casual gaming typically involves low-value transactions, the Company shall implement a risk-based approach to "Know Your Customer" (KYC):

Tiered Verification:

Standard Users: Collection of device ID, email, and IP address.

High-Value Users: Users exceeding specific spending thresholds (e.g., $2,000 in a 24-hour period or $10,000 cumulative) must provide government-issued ID and proof of address.

Verification Prohibitions: No accounts shall be created for anonymous users wishing to conduct high-value virtual asset transfers.

2.2 Transaction Monitoring

The Company's automated systems shall monitor for patterns indicative of money laundering, including:

Structuring (Smurfing): Multiple small purchases just below reporting thresholds.

Rapid Cycling: Rapid funding of an account followed by requests for refunds or transfers to other users.

Dormant Account Spikes: Sudden high-volume activity on a previously inactive account.

Multi-Accounting: One individual operating multiple accounts to bypass spending limits.

2.3 Suspicious Activity Reporting (SAR)

In accordance with FinCEN regulations, the Company will file a Suspicious Activity Report (SAR) if it knows, suspects, or has reason to suspect that a transaction (or a pattern of transactions) involves $5,000 or more in funds derived from illegal activity or is intended to hide funds from illegal activity.

3. ANTI-FRAUD POLICY

3.1 Payment and Chargeback Fraud

To protect the Company's revenue and reputation, the following measures are enforced:

Velocity Checks: Limits on the number of failed payment attempts within a specific timeframe.

3D Secure (3DS): Implementation of 3DS for high-risk credit card transactions.

Refund Management: Systematic tracking of "Friendly Fraud" (legitimate players claiming unauthorized transactions to get refunds). Accounts with excessive chargeback rates will be permanently suspended.

3.2 Account Takeover (ATO) Protection

MFA Implementation: Multi-factor authentication is required for sensitive account changes (e.g., changing linked bank accounts or high-value currency transfers).

Geofencing & IP Analysis: Flagging logins from high-risk jurisdictions or IPs associated with known proxy/VPN services.

3.3 Virtual Economy Integrity

Anti-Botting: Deployment of heuristic analysis to detect automated scripts used for "gold farming" or resource exploitation.

Grey Market Prohibition: Strictly prohibiting the sale of accounts or in-game currency on third-party platforms (e.g., eBay, player-to-player marketplaces).

4. SANCTIONS COMPLIANCE (OFAC)

The Company strictly prohibits providing services to individuals or entities located in countries subject to U.S. comprehensive sanctions (e.g., Iran, North Korea, Syria, Cuba, and occupied regions of Ukraine).

Screening: All high-value users and payout recipients are screened against the OFAC Specially Designated Nationals (SDN) List.

Blocking: Any transaction involving a sanctioned party will be rejected and blocked immediately.

5. DATA PRIVACY AND RECORD KEEPING

Retention Period: The Company shall maintain records of all KYC documentation and transaction logs for a minimum of five (5) years after the account is closed or the transaction is completed.

COPPA Compliance: As a casual gaming company, SkillSphere Game Inc. will not knowingly collect personal information from children under 13 without verifiable parental consent, as required by the Children's Online Privacy Protection Act (COPPA).

6. PENALTIES FOR NON-COMPLIANCE

Failure to comply with this policy may result in:

Immediate termination of user accounts.

Forfeiture of in-game assets.

Reporting to law enforcement agencies (FBI, FinCEN, or local authorities).

Internal disciplinary action for employees, up to and including termination.