Compliance

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

Company Name: SkillSphere Game Inc.

1. INTRODUCTION AND PURPOSE

• 1.1 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.

• 1.2 The Company is committed to maintaining high standards of integrity and compliance. In accordance with applicable U.S. laws and regulations (including the USA PATRIOT Act and guidelines overseen by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC)), the Company implements risk-based anti-fraud and sanctions controls.

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:

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

o 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.

• Behavioral Triggers: Regardless of transaction amount, KYC verification shall be triggered if a user exhibits suspicious behavior, such as frequent changes of payment instruments within a short period (e.g., 1 hour) or spending patterns that significantly deviate from the average player baseline.

• 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), Rapid Cycling, Dormant Account Spikes, and Multi-Accounting.

2.3 Internal Reporting and Compliance Collaboration

The Company maintains internal protocols to identify and escalate transactions (or patterns of transactions) suspected of involving funds derived from illegal activity. As the Company is not a regulated financial institution, it shall provide necessary data support to its payment processors and acquiring banks to assist in their regulatory filing obligations (such as SARs). Furthermore, the Company will cooperate with law enforcement agencies and submit relevant information when required by law or to protect the integrity of its platform.

3. ANTI-FRAUD AND VIRTUAL ECONOMY POLICY

3.1 Payment and Chargeback Fraud

The Company enforces velocity checks, 3D Secure (3DS) for high-risk transactions, and systematic tracking of "Friendly Fraud". Accounts with excessive chargeback rates will be permanently suspended.

3.2 Closed-Loop Payout and Refund Policy

The Company strictly adheres to the principle of returning funds to their original source. Any refunds or incentive payouts must be returned to the original account or payment instrument used for the initial transaction. Transferring or refunding funds from one user account to a different financial instrument (Account A to Instrument B) is strictly prohibited.

3.3 Account Takeover (ATO) Protection

Implementation of MFA for sensitive changes and Geofencing/IP analysis to flag high-risk logins.

3.4 Virtual Economy Integrity

• Anti-Botting: Deployment of heuristic analysis to detect automated "gold farming" scripts.

• Grey Market & Third-Party Top-ups: The Company strictly prohibits the sale of accounts/currency on third-party platforms and the use of unauthorized third-party top-up services. The Company reserves the right to permanently ban accounts and confiscate illicitly obtained assets involved in such activities.

4. SANCTIONS COMPLIANCE (OFAC)

The Company strictly prohibits services to individuals/entities in sanctioned regions. All high-value users and payout recipients are screened against the OFAC SDN List.

Payouts, including but not limited to refunds and promotional prizes, shall only be processed after successful OFAC screening.

5. COMPLIANCE GOVERNANCE

The Company has appointed a senior executive as the Anti-Money Laundering (AML) Compliance Officer to oversee the execution of this policy, conduct periodic risk assessments, and serve as the primary liaison with payment partners and law enforcement.

6. EMPLOYEE TRAINING

All employees involved in user payments and account management must participate in AML and anti-fraud training at least once a year. Training records (including attendance and assessment results) shall be retained for five (5) years.

7. DATA PRIVACY AND RECORD KEEPING

Retention of KYC and transaction records for five (5) years and strict adherence to COPPA regulations.

8. PENALTIES FOR NON-COMPLIANCE

Failure to comply may result in:

• Immediate termination of user accounts and forfeiture of assets.

• Reporting to local law enforcement (e.g., FBI) or providing necessary documentation to Payment Partners for their regulatory filings.

• Internal disciplinary action for employees.