The core objective of this AML Policy is to establish a fortified safeguard within CSGOGem to combat money laundering (ML) activities and other financial crimes.

This policy sets forth measures that ensure all stakeholders, including employees, customers, and partners, operate in full compliance with applicable AML laws and regulations. CSGOGem seeks to preserve the integrity of its platform and promote trust within the global financial system.

To ensure the rigorous enforcement of this policy, CSGOGem has appointed a dedicated AML Compliance Officer (AMLCO), who holds paramount responsibility for the prevention of money laundering.

The AMLCO, reporting directly to senior management, ensures that all necessary actions are implemented to mitigate risks. Continuous oversight is performed through senior-level management reviews and comprehensive audits.

CSGOGem’s AML Program is meticulously designed in alignment with:

• EU Directive 2015/849 on the prevention of the use of the financial system for the purposes of money laundering and terrorist financing.
• EU Regulation 2015/847 on the integrity of fund transfers within the EU.
• BE Law of 18 September 2017 on measures aimed at curbing money laundering and the use of cash.
• Comprehensive sanctions imposed by the European Union against individuals and entities linked to unlawful activity.

At CSGOGem, an integral component of our AML strategy is the adoption of stringent Know Your Customer (KYC) protocols. The process includes:

• Verification of official government-issued documents such as passports, national ID cards, or driving licenses.
• Submission of a selfie to ensure authenticity and verification.
• Proof of address verification via recognized documentation, including utility bills or bank statements issued within the last three months.

In addition, ongoing monitoring is conducted to maintain current customer data, particularly for those deemed high-risk, ensuring that changes in behavior or circumstance are identified promptly.

CSGOGem has instituted a multi-tiered system for transaction monitoring, powered by advanced technological tools to detect and respond to suspicious activities that fall outside of conventional patterns. While CSGOGem performs continuous scrutiny of all transactional activity, we place enhanced focus on transactions of significant value and those that display atypical characteristics, ensuring compliance with a risk-based approach.

We monitor transactions for:

• Unusual volume or frequency of activity inconsistent with known customer profiles.
• Use of payment methods or geographical locations associated with high levels of risk.
• Complex, seemingly unstructured transactions aimed at concealing funds' origins.
• Layering or structuring techniques used to break down larger transactions.
• Unverified third-party payments or activities linked to individuals under sanctions or legal scrutiny.

These transactions are flagged for deeper investigation and, if warranted, escalated to regulatory authorities.

In our quest to preserve the integrity of our platform, we screen transactions for potential connections to:

• Terrorist financing.
• Proliferation of weapons of mass destruction.
• Sanctioned individuals or entities, including those listed by the EU, UN, or OFAC.
• Persons linked to organized crime, human trafficking, or drug smuggling.
• Other entities or individuals associated with high-risk industries or geographical regions under embargos.

Moreover, we are committed to ensuring that no problematic payments or tainted funds—such as those linked to criminal activities—enter or circulate within CSGOGem’s coin pools. Transactions that fail to meet this criterion are immediately flagged and subjected to further scrutiny.

CSGOGem ensures that transactions above a certain financial threshold undergo intensified monitoring, without disclosing these parameters to prevent circumvention by malicious actors.

CSGOGem adheres to a stringent process for the identification, review, and reporting of suspicious transactions. When a transaction is flagged as potentially suspicious by our monitoring systems or personnel, it is promptly escalated to our AML team for in-depth analysis. Should the AML team determine that the transaction poses a legitimate risk, it is reported to the Financial Intelligence Unit (FIU) for further investigation.

All employees of CSGOGem undergo extensive training in AML procedures, with an emphasis on recognizing suspicious behavior and understanding the nuances of transaction monitoring tools. Ongoing training ensures that employees remain abreast of evolving regulatory requirements and best practices in combating money laundering.

To ensure full regulatory compliance, CSGOGem maintains comprehensive records of all customer identification and transactional data for a minimum of 10 years. These records are securely stored and available only to authorized personnel. Internal audits are conducted regularly to evaluate the effectiveness of the AML framework, ensuring all systems function optimally.

CSGOGem’s unwavering dedication to combating financial crime is reinforced by its comprehensive AML Policy. We remain vigilant in identifying, monitoring, and reporting suspicious activities to safeguard the integrity of our platform.

For further inquiries or reporting of suspicious activities, please contact: [email protected].