FLEXITECH LLC FZ, (“Gamingty”, “we”, “us”, “our”, and Company) has developed an Anti-Money Laundering and Anti-Terrorist Financing Policy (“AML Policy”) in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering and terrorist financing. Our policies and procedures meet or exceed legislative requirements in the UAE and reflect how we manage the money laundering and terrorist financing risks to Gamingty, providing a robust, compliant platform.
AML & KYC Policy
We are committed to preventing money laundering, terrorism financing and other financial crimes. This AML & KYC Policy explains how we collect, verify and retain customer information, monitor transactions, and report suspicious activity in accordance with UAE laws and international standards. This policy applies to all users of our e-commerce platform, including buyers, sellers/merchants, and other business partners.
1. Legal basis
This policy is implemented in line with UAE AML/CFT laws and regulations, including Federal Decree Law No. (20) of 2018 and related regulatory guidance, and follows Financial Action Task Force (FATF) recommendations. We cooperate with the UAE Financial Intelligence Unit (FIU) and other competent authorities as required.
2. Scope
This policy applies to all customers, merchants, payment providers, and third-party service providers interacting with our platform, whether located in the UAE or abroad.
3. Risk-based approach
We adopt a risk-based approach to AML/CFT. Customers, transactions, payment methods, goods, and jurisdictions are assessed and classified (low/medium/high risk). The extent of verification, monitoring and controls depends on assessed risk.
4. Customer identification & verification (KYC)
Natural persons (buyers, individual sellers)
· At registration, we collect: full name, email, mobile number, date of birth, billing/shipping address and IP/device data.
· Verification methods:
· Email and mobile OTP verification.
· Government identity documents for higher-risk cases or as required by transaction value: Emirates ID for UAE residents, passport or national ID for non-residents.
· Third-party electronic identity verification services as needed.
· Enhanced verification is required for high-value transactions, unusual activity, or when the customer is a merchant or frequent/high-volume buyer.
Legal entities (merchants and corporate customers)
· We collect: business name, trade license or certificate of incorporation, registration number, registered address, VAT details (if applicable), and bank account details for payouts.
· We identify and verify Ultimate Beneficial Owners (UBOs) who directly or indirectly own or control ≥25% of the entity (or a lower threshold if required by law), and senior management where ownership is opaque.
· Documents are verified using government registries and/or third-party verification providers.
5. Simplified & Enhanced Due Diligence
Simplified due diligence (SDD) may be applied to clearly low-risk customers or low-value transactions, subject to ongoing monitoring and velocity limits. Enhanced due diligence (EDD) applies to high-risk customers or situations, including PEPs, customers from high-risk jurisdictions, complex ownership structures, and unusual or high-value transaction patterns. EDD measures include additional identity checks, source-of-funds/wealth documentation, senior management approval, and increased monitoring.
6. Sanctions, PEP and adverse media screening
We screen customers and transactions against applicable sanctions lists (including UN and UAE lists), PEP lists and adverse media. Matches are reviewed and acted upon in line with legal obligations:
· Confirmed sanctions matches result in transaction/account restrictions, asset freezing where required, and immediate reporting to authorities.
· PEPs are subject to EDD and senior management approval before onboarding.
· Credible adverse media will prompt investigation and may lead to account restrictions and STR filing.
7. Transaction monitoring & reporting
Automated and manual monitoring tools detect suspicious patterns such as large or rapid purchases, frequent refunds/chargebacks, structuring, and atypical cross-border activity. We investigate alerts and, where suspicion of money laundering or terrorism financing remains, we will file Suspicious Transaction Reports (STRs) with the UAE FIU and cooperate with law enforcement. We also comply with any statutory reporting obligations.
8. Account and payment controls
· We apply transaction and velocity limits according to verification level and risk tier. Unverified or low-verified accounts face stricter limits.
· Payment methods (cards, bank transfers, e-wallets, COD, third-party processors) are subject to monitoring and due diligence on the payment provider.
· Cash on Delivery (COD) orders and gift card purchases may be restricted, subject to additional checks, or declined for high-risk orders.
9. Recordkeeping and data retention
We retain identity documents, verification results, transaction records, investigation notes and reports in accordance with UAE requirements and our record retention policy for a minimum period of five years or for such period as required by law. Personal data collected for KYC/AML purposes is processed and stored securely, and used only for compliance, fraud prevention, and lawful purposes. See our Privacy Policy for details.
10. Confidentiality and information sharing
Information obtained for AML/CFT purposes is treated as confidential. We may share relevant information with competent authorities (FIU, regulators, law enforcement) and with third-party service providers that support our compliance program, subject to applicable laws and contractual safeguards.
11. Governance, roles and responsibilities
Board and senior management approve and support the AML/CFT framework. A designated MLRO (Money Laundering Reporting Officer) oversees AML compliance, STR filings and liaison with authorities. Our compliance team implements day-to-day monitoring, investigations, staff training and vendor oversight. Internal audit conducts periodic independent reviews of AML controls.
12. Training and awareness
We provide regular, role-based AML/CFT training for employees in onboarding, payments, merchant management, customer support, risk, and compliance. Training is updated for regulatory changes and new typologies.
13. Third-party vendor due diligence
We conduct AML/KYC and contractual due diligence on identity verification providers, payment processors, logistics partners and other vendors who handle customer onboarding, payments or related services.
14. Actions on refusal, suspension and termination
We may refuse to onboard, suspend or close accounts where:
· We cannot satisfactorily verify identity or beneficial ownership.
· There is reasonable suspicion of money laundering, terrorism financing, fraud or other illicit activity.
· Required information or documents are not provided within the requested timeframes.
Affected parties may be notified unless notification would prejudice a criminal investigation or is otherwise prohibited.
15. Policy review and updates
This policy is reviewed at least annually and updated as required to reflect changes in UAE laws, regulatory guidance, FATF recommendations, and business risks. The latest version is published on this page.
Acknowledgement
By using our platform, customers agree to comply with this AML & KYC Policy and to provide accurate information and documents as required to verify identity and ownership.
Effective date: 12/04/2025| Last reviewed: 12/04/2025
Q: Why do you ask for ID and other personal information?
· We’re required by UAE law to verify customer identities to prevent money laundering, terrorism financing and fraud. This helps keep our marketplace safe.
Q: When will you ask me for documents?
· At registration, we collect basic details (name, email, phone, address). We may request government ID (Emirates ID, passport, national ID) or business documents for high-value orders, merchant onboarding, unusual activity, or when required by law.
Q: What documents might you request?
· Individuals: Emirates ID (for UAE residents), passport or national ID.
· Businesses: trade license or certificate of incorporation, registration number, proof of bank account, and details of Ultimate Beneficial Owners (UBOs).
Q: Will you check sanctions and PEP lists?
· Yes. We screen customers against the UAE, UN and other sanctions lists and identify Politically Exposed Persons (PEPs). Matches are reviewed and acted on in accordance with legal requirements.
Q: What happens if you suspect suspicious activity?
· We investigate internally and, if suspicion remains, we report to the UAE Financial Intelligence Unit (FIU) as required. We may temporarily restrict or close accounts pending investigation.
Q: Can I keep using the site without verification?
· You can browse and make low-risk, low-value purchases with basic verification, but higher transaction limits or specific payment methods require full KYC. Unverified accounts face stricter limits.
Q: How long do you keep my documents?
· We retain KYC and transaction records securely for at least five years (or as required by law) after the end of your relationship with us.
Q: How do you protect my data?
· We store personal data securely and use it only for compliance, fraud prevention and legal purposes. See our Privacy Policy for complete details.
Q: Will you tell me if my account is reported or blocked?
· Where legally permitted, we will notify you if your account is restricted or closed. We may withhold notification if it could prejudice an investigation or is prohibited by law.
Q: Who can I contact about KYC/AML or to provide information?
· For AML/KYC inquiries or to submit information, For urgent legal requests: legal@gamingty.com
Q: Where can I read the full Privacy policy?
· The Privacy policy is available here: https://gamingty.com/privacy-policy
If you have any questions or concerns, feel free to contact Support@gamingty.com