1. Introduction
LasMeta Platform is firmly committed to combating money laundering and the financing of terrorism. This policy sets out the measures we take to prevent and detect such illicit activities within the “LasMeta” AI-Enhanced Social Poker Game (“Game”) and the services we provide.
2. Purpose
The purpose of this KYT/AML Policy is to:
2.1 Preventing Money Laundering and Terrorist Financing
LasMeta Platform is dedicated to preventing money laundering, terrorist financing, and any other unlawful activities on the LasMeta platform. We have implemented rigorous procedures and controls designed to detect, prevent, and mitigate the risk of such activities. These include continuous monitoring of transactions, thorough verification processes, and stringent compliance checks to ensure that our platform remains secure and trustworthy.
2.2 Compliance
We are committed to ensuring that all operations on the LasMeta platform comply with applicable Anti-Money Laundering (AML) regulations and Know Your Transaction (KYT) requirements in all jurisdictions where we operate. Our policies and procedures are regularly reviewed and updated to remain aligned with legal obligations and industry best practices, ensuring that our platform adheres to the highest standards of regulatory compliance.
2.3 Transparency
LasMeta Platform fosters a transparent and secure environment for all transactions conducted on the LasMeta platform. We provide clear and comprehensive information regarding our KYT/AML policies to our users and stakeholders, ensuring that all transactions are conducted with full transparency and in compliance with applicable laws. Our commitment to transparency builds trust and confidence among our users, ensuring that all activities on our platform are legitimate and above board.
3. Scope
3.1 Players and Participants
This policy applies to all players and participants within the LasMeta platform's skill-based gaming environment. Every individual who engages in gameplay, social interactions, or any other activities within the LasMeta environment is required to adhere to the KYT/AML guidelines set forth by LasMeta Platform.
3.2 Owners and Operators of Social Gaming Spaces
Owners and operators of social gaming spaces, venues, and other properties within the LasMeta platform are subject to this policy. They must ensure that their activities, as well as the activities of those who use their social spaces, comply with our KYT/AML requirements to prevent any unlawful activities from occurring.
3.3 Buyers and Sellers of Virtual Assets, Including NFTs
All buyers and sellers of virtual assets, including Non-Fungible Tokens (NFTs), on the LasMeta platform are bound by this policy. Whether engaging in transactions, auctions, or other forms of asset exchanges, these individuals must comply with our KYT/AML procedures to ensure that all transactions are transparent, lawful, and secure.
3.4 Employees, Contractors, and Third-Party Service Providers
This policy extends to all employees, contractors, and third-party service providers engaged by LasMeta Platform. Every individual or entity involved in the operation, maintenance, or support of the LasMeta platform is required to follow our KYT/AML guidelines to ensure that our platform remains compliant with applicable laws and free from unlawful activities.
4. Know Your Transaction (KYT) Measures
KYT is a crucial part of our compliance strategy, ensuring that all transactions on the LasMeta platform are lawful and transparent.
4.1 Transaction Monitoring
- • Real-Time Monitoring: We monitor transactions on the LasMeta platform in real-time, focusing on high-value and unusual transactions. Our automated systems flag any suspicious transactions for further investigation.
- • Transaction Thresholds: Specific transaction thresholds have been established, and any transactions exceeding these thresholds are subjected to enhanced scrutiny. This includes large transfers, frequent high-value purchases, or transactions involving newly created accounts.
- • Pattern Recognition: Our KYT system employs pattern recognition to identify abnormal transaction patterns that may indicate potential money laundering activities.
- • Blockchain Monitoring: We monitor $LASM token transactions on the blockchain for suspicious patterns and ensure compliance with blockchain regulations.
4.2 Enhanced Due Diligence (EDD)
- • High-Risk Transactions: Transactions involving high-risk jurisdictions, politically exposed persons (PEPs), or substantial sums of money are subject to Enhanced Due Diligence (EDD). This entails the collection of additional information and the verification of the source of funds.
- • Third-Party Verifications: For high-value or high-risk transactions, third-party services may be employed to verify the legitimacy of the transaction and the identities of the parties involved.
- • Blockchain Analysis: We conduct thorough analysis of blockchain transactions to identify potential risks and ensure compliance with regulatory requirements.
4.3 Suspicious Activity Reporting (SAR)
- • Immediate Reporting: Any suspicious activity detected by our KYT system is immediately reported to the relevant regulatory authorities in compliance with local laws. This includes activities that may suggest money laundering, terrorist financing, or other unlawful conduct.
- • Internal Investigations: We conduct thorough internal investigations of flagged transactions, including the review of transaction histories, communication logs, and associated accounts.
- • Blockchain Investigations: We investigate suspicious blockchain transactions and coordinate with relevant authorities for cross-border compliance.
5. Anti-Money Laundering (AML) Measures
Our AML measures are designed to ensure that all users of the LasMeta platform are legitimate and that their funds are derived from lawful sources.
5.1 Customer Due Diligence (CDD)
- • Identity Verification: All users are required to complete a KYC (Know Your Customer) process, which involves verifying their identity using government-issued identification documents and proof of address.
- • Ongoing Monitoring: User accounts are continuously monitored for suspicious activities, with any changes in behaviour triggering a re-evaluation of the user's risk profile.
- • Source of Funds: Users may be required to provide information regarding the source of their funds, particularly for large transactions or if their activity raises red flags.
- • Blockchain Wallet Verification: We verify the legitimacy of blockchain wallets and monitor for suspicious wallet activities.
5.2 Risk Assessment
- • Risk-Based Approach: We employ a risk-based approach to AML, focusing resources on higher-risk customers and transactions. Users are classified into risk categories, with appropriate levels of scrutiny applied accordingly.
- • Periodic Reviews: Regular reviews of user accounts and transactions are conducted to ensure ongoing compliance with AML regulations.
- • Blockchain Risk Assessment: We assess risks associated with blockchain transactions and implement appropriate controls.
5.3 Training and Awareness
- • Employee Training: All employees and contractors involved in transaction processing or customer interactions receive regular training on AML and KYT best practices. This training is updated regularly to reflect changes in regulations and emerging threats.
- • Awareness Campaigns: Awareness campaigns are conducted for users, educating them about the risks of money laundering and the importance of compliance with our KYT/AML policies.
- • Blockchain Compliance Training: Specialized training is provided for blockchain-related compliance and regulatory requirements.
6. Record Keeping
- • Data Retention: We securely retain all records related to transactions, identity verification, and due diligence for a minimum of five years, as required by law. These records include transaction logs, KYC documentation, and communication records.
- • Audit Trails: Detailed audit trails of all transactions and compliance activities are maintained to provide evidence of compliance during audits or investigations.
- • Blockchain Records: We maintain comprehensive records of blockchain transactions for compliance and audit purposes.
7. Cooperation with Authorities
- • Regulatory Reporting: We fully cooperate with regulatory authorities and provide all required documentation and information during AML audits or investigations.
- • Information Sharing: Where appropriate, we share information with other financial institutions and relevant authorities to prevent and detect money laundering and terrorist financing.
- • Cross-Border Cooperation: We cooperate with international authorities for cross-border compliance and investigations.
8. Blockchain Compliance
As a 100% on-chain economy platform, we maintain additional compliance measures for blockchain transactions:
- • Token Monitoring: We monitor $LASM token transactions for suspicious patterns and ensure compliance with token regulations.
- • Wallet Verification: We verify the legitimacy of blockchain wallets and monitor for suspicious wallet activities.
- • Smart Contract Audits: Regular audits of smart contracts ensure compliance with regulatory requirements.
- • Cross-Chain Monitoring: We monitor transactions across different blockchain networks for compliance purposes.
9. Consequences of Non-Compliance
Non-compliance with this KYT/AML Policy by any user, employee, or contractor will result in serious consequences, including but not limited to:
- • Account Suspension or Termination: User accounts found to be involved in suspicious activities or in violation of our KYT/AML policies will be suspended or permanently terminated.
- • Legal Action: We reserve the right to pursue legal action against individuals or entities involved in money laundering, terrorist financing, or other unlawful activities on our platform.
- • Reporting to Authorities: Any non-compliance will be reported to the relevant regulatory and law enforcement authorities, who may pursue criminal or civil actions.
- • Blockchain Blacklisting: Suspicious wallets may be blacklisted from the platform to prevent further illicit activities.
10. Policy Review and Updates
This KYT/AML Policy is subject to regular review and updates to ensure it remains effective and compliant with the latest legal and regulatory requirements. We are committed to continuous improvement and to adapting to emerging risks in the financial and digital asset sectors.
11. Effective Date
This KYT/AML Policy is effective as of 15.01.2025.
