AML Policy
AML Policy
Policy
ORGANIZATIONAL PROFILE OF UMIIUMII B.V
UmiiUmii B.V. trading as MonkeyTilt is a corporate entity formed under the laws of Curaçao in 2017. It administers the online gaming site at www.monkeytilt.com operating under license number 8048/JAZ2021-080,and caters to a diverse international clientele. MonkeyTilt has instituted a series of compliance safeguards, appropriately scaled to its range of services and products, aimed at deterring and identifying potential illegal activities within its digital environment.
POLICY PROCLAMATION
Although MonkeyTilt is not recognized as a financial institution under the prevailing laws of Curaçao, it adheres to the 2016 Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations as stipulated by the Curaçao Gaming Control Board. This policy stringently prohibits the use of MonkeyTilt's services for any unlawful endeavours, encompassing money laundering, terrorist financing, and breaches of trade sanctions, in line with various international AML legislations and the directives of the Financial Action Task Force (FATF) and associated gaming bodies. The policy encompasses:
- The formulation and upkeep of a documented policy, procedures, and controls specifically designed to prevent money laundering and terrorist financing;
- The nomination of a compliance officer to manage and ensure the efficacy of these policies and controls;
- Regular educational programs and training for personnel relevant to these policies; and
- Continuous independent evaluations and enhancements of these policies and controls.
Definition
“Suspicious Activity” means activities or transactions on the platform that raise concerns of potential illegal or fraudulent motives.
“Sanctions” means International mandates aimed at limiting or directing the actions of specific countries, entities, or individuals.
“Layering” involves disguising the origins of illegal funds through complex financial transactions. This process, which includes converting cash into various forms and investing in different assets, aims to sever the link between the money and its criminal source.
“Integration” is the final stage where laundered money is reintroduced into the economy as legitimate. It involves using seemingly legal transactions to mask the illicit origins of the funds, allowing them to be used without suspicion.
REGULATORY GOVERNANCE AND OVERSIGHT
The Chief Compliance Officer (CCO) at MonkeyTilt holds responsibility for the administration and execution of the AML Policy. Responsibilities include formulating AML strategies, updating policies as required, evaluating new regulatory requirements, and probing into atypical or suspicious activities. MonkeyTilt ensures all its employees undergo regular training in AML practices.
CLIENT DUE DILIGENCE AND TRANSACTION MONITORING
MonkeyTilt undertakes due diligence and continuous monitoring in compliance with legal standards with an aim to deter users from participating in illegal or unauthorized activities. This is achieved through a mix of software solutions and service agreements, reinforced by internal procedures to ensure adherence to relevant laws.
KNOW YOUR CUSTOMER (KYC)
Customer Due Diligence (CDD)
MonkeyTilt employs a risk-based CDD approach to understand user interactions with its platform and establish a customer risk profile. This involves collecting both documentary and non-documentary information when opening an account, tailored to the type of account and services offered by MonkeyTilt. Different CDD standards apply to various accounts and services.
For example, users must complete MonkeyTilt's customer identification program (CIP), which includes:
- Gathering basic information (e.g, full name, DOB, wallet address and email) during account setup via MonkeyTilt's user onboarding portal;
- Continued monitoring risks associated with the cryptocurrency wallet funding the account;
- Keeping records of user identification information, and updating intermittently; and
- Checking if users are on any lists of known or suspected terrorists or terrorist organizations.
These steps are implemented through:
- Identity, Age and Address Verification: A third-party service verifies the authenticity of identification and other KYC materials, ensuring users are permissible and not located in sanctioned or prohibited jurisdictions. It also checks global sanctions lists using onboarding information like wallet addresses.
- Customer Information: MonkeyTilt collects information to confidently identify its users, in line with their risk profile. This may include wallet address, name, address, country, date of birth, or postal code. This information is gathered before issuing a MonkeyTilt funding address to users. Currently, MonkeyTilt does not serve non-natural persons and may rely on other institutions for some CIP elements.
- Geo-blocking for Prohibited and Sanctioned Jurisdictions: Monkey Tilt requires client certifications for IP address-based geo-blocking to prevent offering services in countries where it's illegal or users are under U.S., EU, or other global sanctions.
- Contractual Restrictions for Users from Prohibited Jurisdictions: Users are informed during onboarding about service restrictions in certain jurisdictions, based on Monkey Tilt's risk, fraud prevention, and AML policies.
Enhanced Due Diligence and Ongoing Monitoring
For example, users must complete MonkeyTilt's customer identification program (CIP), which includes:
- Gathering basic information (e.g, full name, DOB, wallet address and email) during account setup via MonkeyTilt's user onboarding portal;
- Continued monitoring risks associated with the cryptocurrency wallet funding the account;
- Keeping records of user identification information, and updating intermittently; and
- Checking if users are on any lists of known or suspected terrorists or terrorist organizations.
MonkeyTilt conducts regular monitoring to identify potential money laundering or terrorism financing activities. This involves using red flag indicators to detect suspicious behaviors, leading to enhanced due diligence if triggered. Enhanced KYC includes verifying:
- Full legal name;
- Residency or Citizenship;
- Permanent address;
- Identification number (taxpayer ID, passport number, alien ID card number, etc.);
- Identification document;
- If required, source of funds and wealth.
Third-party services are used for verification to establish the true identity of users with suspicious activities.
Acceptance Policy
MonkeyTilt will block users who
- Fail to provide requested identification information;
- Submit false identification documents;
- Misrepresent their location;
- Are from restricted or prohibited jurisdictions;
- Are subject to U.S., EU, or other global sanctions or watch lists;
- Have gambling addiction or mental health issues;
- Have funds originating or exchanged in restricted jurisdictions.
MonkeyTilt reserves the right to block or suspend users for other reasons at its discretion.
TRANSACTION MONITORING
MonkeyTilt is dedicated to adhering to economic and trade sanctions programs in its operational jurisdictions. To this end, MonkeyTilt has established a transaction monitoring program with robust controls and processes to identify and address any unusual activities in real-time and through ongoing surveillance.
Regular Monitoring and System Implementation
MonkeyTilt conducts continuous monitoring using a combination of in-house rule-based systems and third-party vendor solutions. These systems review user history and activity patterns to identify and report any unusual activities, including on-chain activity, as well as to develop and implement additional controls or limitations on its platform.
Key Components of Unusual Activity Management
MonkeyTilt's procedures focus on two main aspects:
- Identifying unusual activities through various methods, including employee and customer reports, law enforcement inquiries, other referrals, or reports from transaction and surveillance monitoring systems.;
- Managing alerts through processes for investigating, evaluating, and documenting identified unusual or potentially suspicious activities.
Processes for Achieving Monitoring Goals
- Monitoring Transactions in Sanctioned or Prohibited Jurisdictions: MonkeyTilt may impose due diligence requests during user balance withdrawals and employs a mix of manual and automated processes to identify red flag behaviors. This includes restricting account funding from prohibited jurisdictions and screening for U.S. based exchange wallets.
- Screening for Sanctioned Parties: Before issuing a MonkeyTilt funding address, user wallet addresses are screened against sanctions databases using third-party blockchain forensics vendors like Chainalysis.
- Identifying Unusual Activities: MonkeyTilt monitors account activities for unusual sizes, volumes, patterns, or types of transactions, considering risk factors and red flags.
- Anti-Mixing Measures: MonkeyTilt uses software to detect suspicious deposit or withdrawal patterns, requiring users to explain their actions in high-risk cases.
- Chainalysis Review: All crypto transactions are reviewed through Chainalysis for signs of fraud or suspicious behavior, with potential account suspension and review for high-risk accounts.
- Withdrawal Threshold KYC: Accounts reaching a certain withdrawal threshold undergo enhanced KYC diligence based on their risk characterization.
Additional Ongoing Monitoring Controls
- Ban Evasion Detection: MonkeyTilt uses third-party software to detect multiple account usage by a single user, requiring explanations in high-risk cases.
- Time Zone Monitoring: Controls are in place to detect discrepancies in user device information and location, identifying potential use of geo-location software to mask actual jurisdictions.
- Products and Services Review: MonkeyTilt establishes procedures to prevent misuse of its platform, including policies on asset onboarding and prohibiting anonymity-enhancing technologies.
- Vendor Management: MonkeyTilt assesses and manages third-party service providers to ensure compliance with its policies.
- Compliance Innovation: MonkeyTilt continuously evaluates non-documentary compliance mechanisms, including blockchain-native tools like on-chain KYC providers and fraud prevention services.
MonkeyTilt's comprehensive approach to transaction monitoring and ongoing controls reflects its commitment to compliance and risk management in its operations.
EDUCATIONAL PROGRAMS AND TRAINING
MonkeyTilt commits to providing its employees with regular training sessions on AML, counter- terrorist financing, and adherence to trade sanctions, under the guidance of the CCO and with legal counsel's assistance.
COMPLIANCE REPORTING
In line with national regulations, MonkeyTilt is dedicated to reporting any transactions that are unusual or warrant suspicion. This includes identifying and reporting customers implicated in money laundering, terrorism financing, or other criminal activities to the appropriate regulatory bodies.
MonkeyTilt is owned and operated by UmiiUmii B.V., registration number: 154512, registered address: Fransche Bloemweg 4, Curacao.Contact us at support@monkeytilt.com Payment agent company is Green Cage Ltd with address Βουκουρεστίου, 25,Neptune House, Floor 1, Flat/Office 11, Ζακάκι 3045, Λεμεσός, Κύπρος, Cyprus and Registration number: HE412827