Gamingty LTD (“Gamingty”, “we”, “us”, “our”, and “Company”) has developed this Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML Policy”) to maintain compliance with applicable UK laws and regulations relating to anti-money laundering, counter-terrorist financing, fraud prevention, sanctions compliance, and financial crime risk management.
We are committed to preventing money laundering, terrorist financing, fraud, sanctions breaches, 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 UK legal and regulatory requirements and international standards.
This policy applies to all users of our e-commerce platform, including buyers, sellers/merchants, corporate customers, payment partners, vendors, and other business partners.
1. Legal basis
This policy is implemented in line with applicable UK AML/CTF laws and guidance, including the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000, UK sanctions requirements, and relevant guidance issued by UK supervisory authorities including HMRC, the FCA where applicable, and the National Crime Agency (“NCA”).
2. Scope
This policy applies to all customers, merchants, payment providers, third-party service providers, and business partners interacting with our platform, whether located in the United Kingdom or abroad.
3. Risk-based approach
We adopt a risk-based approach to AML/CTF. Customers, transactions, payment methods, goods, services, merchants, and jurisdictions are assessed and classified as low, medium, or high risk. The level of verification, monitoring, and control applied depends on the assessed risk.
4. Customer identification & verification — KYC/CDD
Natural persons — buyers and individual sellers
At registration or when required, we may collect:
- Full name
- Email address
- Mobile number
- Date of birth
- Billing and shipping address
- IP address and device data
- Payment-related information
Verification methods may include:
- Email and mobile OTP verification
- Government-issued identity documents, such as passport, UK driving licence, national identity card, or biometric residence permit
- Proof of address, where required
- Third-party electronic identity verification services
Enhanced verification may be required for high-value transactions, unusual activity, repeated or high-volume purchases, merchant activity, or where required by law.
Legal entities — merchants and corporate customers
For businesses, we may collect:
- Registered business name
- Company registration number
- Registered office or trading address
- VAT number, if applicable
- Bank account details for payouts
- Certificate of incorporation or equivalent business registration document
- Details of directors, authorised representatives, and Ultimate Beneficial Owners (“UBOs”)
We identify and verify UBOs who directly or indirectly own or control 25% or more of the entity, or a lower threshold where required by law or risk assessment. Where ownership is complex or opaque, we may also verify senior management and request additional documents.
5. Simplified and Enhanced Due Diligence
Simplified Due Diligence (“SDD”) may be applied to clearly low-risk customers or low-value transactions, subject to ongoing monitoring and transaction limits.
Enhanced Due Diligence (“EDD”) applies to higher-risk customers or situations, including:
- Politically Exposed Persons (“PEPs”)
- Customers from high-risk jurisdictions
- Complex ownership structures
- Unusual, high-value, or suspicious transaction patterns
- Higher-risk merchants or product categories
EDD may include additional identity checks, source-of-funds or source-of-wealth information, senior management approval, and increased ongoing monitoring.
6. Sanctions, PEP, and adverse media screening
We screen customers, merchants, transactions, and relevant business partners against applicable sanctions lists, including UK sanctions lists and other relevant international lists where appropriate.
Confirmed sanctions matches may result in account restrictions, transaction blocking, asset freezing where required, and reporting to the relevant UK authorities.
PEPs are subject to enhanced due diligence and senior management approval before onboarding or continued use of the platform. Credible adverse media may trigger further investigation and may result in account restrictions, refusal, suspension, termination, or reporting.
7. Transaction monitoring and reporting
We use automated and manual monitoring to detect suspicious activity, including:
- Large or rapid purchases
- Frequent refunds or chargebacks
- Structuring or split transactions
- Unusual cross-border activity
- Inconsistent customer behaviour
- Suspicious merchant or payout activity
Where suspicion of money laundering or terrorist financing remains after internal review, we may submit a Suspicious Activity Report (“SAR”) to the UK Financial Intelligence Unit within the National Crime Agency (“NCA”). SARs are used in the UK to report suspected money laundering and terrorist financing.
8. Account and payment controls
We may apply transaction limits, velocity limits, payment restrictions, payout holds, or additional checks based on verification level and risk tier.
Unverified or partially verified accounts may face stricter limits.
Payment methods including cards, bank transfers, e-wallets, gift cards, COD, and third-party payment processors are subject to monitoring and due diligence. High-risk orders may be restricted, delayed, reviewed, or declined.
9. Recordkeeping and data retention
We retain identity documents, verification results, transaction records, investigation notes, screening results, and reports in accordance with applicable UK legal and regulatory requirements.
Records are retained securely for at least five years, or longer where required by law, regulation, dispute handling, fraud prevention, or law enforcement purposes.
Personal data collected for AML/KYC purposes is processed securely and used only for compliance, fraud prevention, risk management, and lawful business purposes. Please refer to our Privacy Policy for more information.
10. Confidentiality and information sharing
Information obtained for AML/CTF purposes is treated as confidential.
We may share relevant information with competent authorities, law enforcement, regulators, supervisory bodies, payment providers, identity verification providers, fraud prevention agencies, and other third-party service providers where lawful and necessary.
We do not disclose SAR filings or suspicious activity investigations where doing so would breach legal obligations or prejudice an investigation.
11. Governance, roles, and responsibilities
Senior management approves and supports the AML/CTF framework.
A designated Money Laundering Reporting Officer or nominated officer oversees AML compliance, internal suspicious activity reviews, SAR submissions, staff training, and liaison with relevant authorities.
Our compliance team is responsible for day-to-day monitoring, investigations, onboarding reviews, merchant due diligence, vendor oversight, and recordkeeping.
12. Training and awareness
We provide regular, role-based AML/CTF and financial crime training to relevant employees, including teams involved in onboarding, payments, merchant management, customer support, fraud prevention, risk, and compliance.
Training is updated to reflect legal changes, new typologies, and business risks.
13. Third-party vendor due diligence
We conduct due diligence on third-party vendors that support onboarding, identity verification, payments, logistics, fraud prevention, compliance screening, or transaction processing.
Vendors may be subject to contractual controls, security requirements, monitoring, and periodic review.
14. Refusal, suspension, and termination
We may refuse onboarding, suspend, restrict, or close accounts where:
- We cannot verify identity or beneficial ownership
- Required information or documents are not provided
- We suspect money laundering, terrorist financing, fraud, sanctions evasion, or other illicit activity
- The customer, merchant, or transaction presents unacceptable risk
- Continuing the relationship may breach legal or regulatory obligations
Affected parties may be notified where legally permitted. We may withhold notice where notification is prohibited or could prejudice an investigation.
15. Policy review and updates
This policy is reviewed at least annually and updated as required to reflect changes in UK laws, regulatory guidance, sanctions requirements, FATF recommendations, business risks, and platform operations.
The latest version is published on this page.
Effective date: 12/04/2025
Last reviewed: 12/04/2025
Customer FAQs
Q: Why do you ask for ID and personal information?
We may be required to verify customer identities to prevent money laundering, terrorist financing, fraud, sanctions breaches, and other financial crime.
Q: When will you ask me for documents?
We collect basic details at registration. We may request ID, proof of address, business documents, or additional information for high-value orders, merchant onboarding, unusual activity, payment reviews, or legal compliance.
Q: What documents might you request?
For individuals, we may request a passport, UK driving licence, national ID card, biometric residence permit, or proof of address.
For businesses, we may request company registration documents, VAT details, bank account proof, director information, and UBO details.
Q: Will you check sanctions and PEP lists?
Yes. We screen customers, merchants, and transactions against relevant sanctions, PEP, and adverse media sources.
Q: What happens if you suspect suspicious activity?
We investigate internally and, where appropriate, submit a SAR to the NCA. We may temporarily restrict, delay, or close accounts during review.
Q: Can I keep using the site without verification?
You may be able to browse or make low-risk, low-value purchases with basic verification. Higher limits, merchant accounts, specific payment methods, or higher-risk activity may require full KYC.
Q: How long do you keep my documents?
We retain KYC and transaction records securely for at least five years, or longer where required by law.
Q: How do you protect my data?
We store personal data securely and use it only for lawful purposes, including compliance, fraud prevention, risk management, and legal obligations.
Q: Will you tell me if my account is reported or blocked?
Where legally permitted, we may notify you if your account is restricted or closed. We may withhold notification where required by law or where disclosure could prejudice an investigation.
Q: Who can I contact about AML/KYC?
For AML/KYC inquiries or to submit information, contact: [email protected]
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, please contact [email protected]