- Preliminary
a) This anti-money laundering (“AML”) and know-your-customer (“KYC”) policy (“AML and KYC Policy”) is issued by COG Holdings Global Limited (“COG” or “Us” or “We” or “Our”) and forms a legally binding agreement between you (“User” or “You” or “Your”) and Us. It applies to Your use of the Platform and Our Services.
b) HIS AML AND KYC POLICY IS PART OF OUR TERMS OF USE AND SHALL BE SUBJECT TO AND READ ALONG WITH OUR TERMS OF USE, AVAILABLE AT COG . ALL CAPITALIZED TERMS USED AND NOT DEFINED HEREIN SHALL HAVE THE MEANING ASCRIBED TO THEM UNDER THE TERMS OF USE.
c) This AML and KYC Policy is meant to provide You with necessary information in relation to the manner in which we comply with AML regulations and conduct KYC on the Users
- Our Commitment to AML
a) COG is committed to carrying on its business in accordance with the highest ethical and business standards. This includes complying with all Applicable Laws and regulations aimed at combating money laundering and related illegal activities.
b) COG understands that money laundering undermines legitimate business activities, facilitates and breeds corruption, damages the legitimate rights and interests of Users, and severely impacts the functioning and perception of the digital economy.
c) COG has formulated this AML and KYC Policy, to be read along with the Terms of Use and our Privacy Policy, to prevent money laundering and terrorist financing and fully comply with Applicable Laws in this regard.
- Applicability
a) This AML and KYC Policy shall apply to all Users on the Platform.
b) This AML and KYC Policy will be governed by and shall be construed in accordance with the laws of British Virgin Islands. Where there are stricter requirements in the country or region where the Users are located, such requirements shall prevail.
- Principles
a) The Platform will take into account all kinds of risk factors on the basis of which Users may be suspected of money laundering, and will monitor risks of all Users in a proportionate manner.
b) The Platform may classify Users into different categories and monitor their transactions from time to time, and take such measures as required under Applicable Law.
c) The Platform will constantly improve its ability to authenticate User identities and monitor suspicious Users and/or suspicious transactions in a prudent way.
d) The Platform will respond to identified risks on the basis of their actual and specific circumstances.
e) Information held by the Platform in relation to User identities, transactions and risk levels shall be kept strictly confidential and shall only be shared or processed in accordance with our Privacy Policy.
- User Identification
a) COG takes reasonable and industry-standard measures to establish the identity of a User to whom it provides its Services.
b) COG, with the help of its Service Providers, collects User identification details from each User, including but not limited to the following:
name;
address;
contact number;
e-mail address;
PAN /Tax ID;
any other government-issued photo identification document of the User;
other information or documents as may be required by the Platform or its Service Provider, including for the purpose of enhanced due diligence.
c) Users who want to withdraw Earnings from their Third-Party Wallet to their bank account are required to verify their bank accounts by providing valid photo identification document(s) and address proof document(s) for proof of identity and residence, and such other information as required by our Service Provider or as mandated by Applicable Law. Failure to provide the requisite identification documents (to COG’s or its Service Provider’s satisfaction) may result in the denial or restriction in withdrawals of Earnings by COG.
d) Withdrawals may also be subject to additional jurisdiction-specific document verification requirements and geo-location verification.
e) COG reserves the right to seek further documents from Users for KYC verification, in accordance with Applicable Laws and in the interests of security, customer service, customer due diligence and other compliance requirements.
f) The Platform only accepts documents in language which are admissible under local laws.
g) The Platform retains an absolute right to undertake measures in accordance with Applicable Laws to identify the actual or beneficial owner or controller of a User Account.
h ) The Platform retains the right to set and adjust, at any time, the maximum amount of earnings that may be withdrawn in a given time period.
- Transaction Monitoring
a) The Platform monitors User activity on the Platform on an ongoing basis in accordance with the best industry practices and in alignment with international recommendations, guidelines, and commitments. Such monitoring may be performed using rule-based systems developed in-house and/or by third parties, to:
review User history and activity patterns,
check for unusual or suspicious behaviour/transactions, and
implement additional controls or limits on the Platform.
b) The Platform retains, at all times, an unconditional and absolute right to verify suspicious transactions and/or suspicious accounts in accordance with Applicable Laws, including but not limited to the following circumstances:
withdrawals or transactions from the Third-Party Wallet which are clearly inconsistent with the User’s identity, financing standing and/or past activity;
where a User Account that has been inactive for a long time is suddenly reactivated, or there is a sudden and abnormal in-flow of digital assets in an account with usually small amounts of digital asset flow, and a large amount of digital assets are withdrawn/ transferred within a short period of time;
where a large number of User Accounts are opened or deleted without any justifiable reason, and a large amount of digital assets are deposited or withdrawn prior to such deletion of accounts;
- the User fails to provide valid identification documents;
- the User fails to update his/her profile without any justifiable reason;
- where the Platform doubts the authenticity, validity and/or integrity of the User’s identity information;
- the User forges or alters his or her identification documents to deceive the Platform;
- the User’s explanation for a suspicious transaction is unjustifiable;
- any other suspicious situations/transactions as may be identified by the Platform.
c) The Platform retains, at all times, an unconditional and absolute right to suspend/freeze/block/deactivate User Accounts and decline/reject/cancel withdrawal requests where such suspicious transaction(s) are noticed.
- Miscellaneous
a) Users are prohibited from:
lending their User Account details to any other person;
renting out or lending their identity documentation(s);
renting out, lending or disclosing important personal information, such as their User Account details and password.
b) By signing up for a User Account You confirm that You are submitting accurate and up-to-date personal information that belongs to You and that You will not use the Platform and Our Services to commit any listed or criminal offences or money laundering or terrorist financing activities.
c) Users shall actively cooperate with the Platform in its User identification processes.
d) Users may report to the Platform if they find that any User Account may be engaged in money laundering or terrorist financing activities. You may write to: legal@circleofgames.com
