Anti-money Laundering Policy

Anti-Money Laundering Policy

Fairfox maintains this Anti-Money Laundering Policy (the Policy) to prevent the platform from being used for money laundering, terrorist financing, or other illicit purposes. The Policy governs Fairfox operations, including all employees, contractors, and users of Fairfox services, and aligns with applicable AML/CFT laws and regulatory expectations in the jurisdictions in which Fairfox operates.

Scope and Application

This Policy applies to all Fairfox products and services, including online platforms, payment processing, and customer onboarding. It requires the implementation of risk-based controls consistent with the nature of Fairfox’s customers, products, services, and geographies. Compliance is mandatory for all personnel and contracted partners acting on behalf of Fairfox.

Risk Assessment and Governance

• Fairfox conducts an ongoing risk assessment to identify and mitigate Money Laundering and Terrorist Financing risks. The assessment covers geographic exposure, customer types, products and services offered, and channels used for engagement and payment processing.
• Risks are categorized into geographic risk (residence jurisdiction and high-risk regions), customer risk (including Politically Exposed Persons), product risk (high‑volume or high‑value offerings), and channel risk (digital onboarding, mobile access, or alternative payment methods).
• Oversight rests with the designated AML Compliance Officer and senior management, who approve the risk framework and authorize escalation and remediation actions when warranted.

Customer Identification and Verification (KYC)

Fairfox shall establish the identity of each User prior to providing services that involve the movement of funds or access to payout features. The onboarding workflow collects minimum information and documents sufficient to verify identity and lawful possession of funds.

• Minimum data: full legal name, date of birth (must be at least 18 years old), residential address, nationality, valid contact details, and a user-specific identifier.
• Documentation: government-issued photo ID (passport, national ID card), and proof of address (utility bill, bank statement not older than 3 months, or other documents allowed by applicable law).
• Account opening shall not be completed using anonymous or fictitious information. The true beneficial owner must be identifiable for all accounts.
• Verification triggers: before processing any payment or payout exceeding 1,000 EUR per occasion, or when a payout is requested, identity verification must be completed; additional verification may be required if risk indicators are present.
• Ongoing verification: Fairfox may request updated documentation if information changes or if risk indicators arise. If a User refuses to provide required information or provides misleading data, Fairfox may suspend or terminate the account and report the matter to the AML regulator if required by law.
• Data retention: identity and verification documents, along with related transaction data, shall be retained in accordance with applicable data protection laws and regulatory obligations.

Continuous Transaction Monitoring and Ongoing Due Diligence

Fairfox implements ongoing monitoring to identify unusual or suspicious activity and to understand the purpose and legitimacy of transactions.

• Automated transaction monitoring: all transactions are subject to automatic screening, with a focus on size, frequency, counterparties, and patterns that diverge from established user behavior.
• Reporting thresholds: activity exceeding 1,000 EUR requires review, with enhanced scrutiny for multiple smaller transactions that collectively breach risk thresholds.
• Human review: the AML Compliance Officer is responsible for reviewing flagged activity, determining the need for further information, and deciding on escalation or escalation to authorities where appropriate.
• Payment flows: funds may be received by the following non-cash methods only, and must be capable of traceability: credit cards, debit cards, electronic transfers, bank transfers, checks, or other regulator-approved methods. Fairfox shall generally credit and settle payouts using the same method that funds were received, where feasible.
• Record of monitoring: Fairfox shall maintain an auditable log of monitoring activities and findings, including dates, nature of checks performed, and actions taken.

Payments, Transfers and Third-Party Arrangements

Funds accepted and disbursed by Fairfox must be traceable to legitimate sources and flows. The following controls apply:

• No cash payments: Fairfox does not accept cash. All payments must be traceable through electronic means or other regulator-approved channels.
• Source of funds: ultimate source of funds may be requested to satisfy due diligence requirements, especially for high-risk transactions or out-of-pattern deposits.
• Payment routing: refunds and winnings shall be returned through the same payment route used for the original funding where practicable and legally permissible.
• Prohibition on third-party payments: funds submitted to an account must be in the name of the registered User. Where third-party involvement is detected, Fairfox may suspend the transaction and request further verification.
• Inter-user transfers: transfers between User accounts are prohibited unless expressly authorized under a regulated program or payout arrangement.
• Third-party processors: if a third-party processor is used, Fairfox ensures the processor maintains transaction monitoring and complies with applicable AML controls. The AML Compliance Officer reviews the service agreement to confirm adequacy of AML provisions.
• Recordkeeping: all financial records, including transaction data and supporting documents, are maintained as required by applicable AML and data protection laws.

Suspicious Transactions and Reporting

Fairfox shall identify, investigate, and report suspicious activities in a timely and compliant manner.

• Suspicious activity triggers: any transaction or series of transactions involving 1,000 EUR or more that raises concerns such as unusual patterns, mismatched origin of funds, or involvement of sanctioned or high-risk entities.
• Internal escalation: the AML Compliance Officer shall, upon detection or suspicion, collect additional information, coordinate with relevant departments, and determine whether to file a report with the appropriate authorities.
• Regulatory disclosures: Fairfox shall file any required suspicious activity reports (or equivalent notices) in accordance with local law and regulatory requirements, and preserve relevant documentation for the legally required retention period.

Training and Awareness

Fairfox maintains an ongoing training program to ensure staff understand AML/CFT obligations and how to recognize and respond to suspicious activity.

• Training frequency: at least annually, with additional sessions when there are regulatory or product changes that affect risk exposure.
• Curriculum: includes identification of money laundering and terrorist financing indicators, KYC procedures, escalation paths, and data protection considerations.
• Documentation: completion records are maintained for audit and regulatory review.

Roles and Responsibilities

The following roles are responsible for implementing and enforcing this Policy:

• AML Compliance Officer: oversees the design, execution, and ongoing effectiveness of AML controls, coordinates investigations, and reports to senior management.
• Senior Management: ensures adequate resources and authority to enforce the Policy; approves changes to risk frameworks and escalation procedures.
• All staff and contractors: comply with KYC, transaction monitoring, and escalation procedures as part of their duties.

Data Protection, Records Retention and Privacy

Fairfox preserves data in accordance with applicable data protection and privacy laws. Records relating to customer identification, transactions, and due-diligence should be kept for a minimum period defined by law or regulatory guidance, and in any event long enough to support ongoing AML monitoring and regulatory reporting requirements. Access to sensitive information is restricted to authorized personnel and protected using appropriate technical and organizational security measures.

Amendments and Updates

This Policy may be amended from time to time. Fairfox will notify Users of material changes in accordance with applicable regulatory and contractual requirements. Continued use of Fairfox services after the effective date of changes constitutes acceptance of the updated Policy.

Sanctions Screening and Compliance with Prohibitions

Fairfox screens users, transactions, and counterparties against applicable sanctions and embargo lists and other relevant high‑risk indicators. If a User is found to be subject to sanctions or is identified as a high‑risk individual or entity, Fairfox will immediately suspend activity, freeze accounts where warranted, and report the matter to the relevant authorities in accordance with law.