Introduction
In order to conduct business, GamesCodeSale strives to uphold the highest ethical standards. This includes abiding by all applicable laws and rules prohibiting the financing of terrorism and money laundering. In order to actively avoid and minimize the risks of money laundering and the support of terrorist or criminal activities in our business, we have established this anti-money laundering and terrorist financing policy (also known as an AML policy).
The management of GamesCodeSale pledges to abide by all anti-money laundering and terrorist financing laws and regulations (commonly referred to as "AML laws"). However, GamesCodeSale also expects its directors, employees, interns, customers, suppliers, and contractors to do the same. Therefore, breaking the rules outlined in this AML policy may result in punishment or the breakup of a business partnership.
GamesCodeSale Policy Statement on AML
The GamesCodeSale is aware of its duty and responsibility to make sure that its operations around the world abide by all applicable AML rules. This policy was created to reassure all third parties, including customers, suppliers, and contractors, that we make every attempt to uphold the highest operational standards. Only legal businesses with finances coming from legitimate sources are allowed to work with GamesCodeSale.
With the help of this policy, GamesCodeSale hopes to inform its employees and other parties about how to make moral decisions while representing or working for GamesCodeSale. This policy should outline what to consider when beginning or maintaining games distributing partnerships in the context of adhering to AML rules and offer advice in situations of (suspected) AML law violations.
Respect for this policy is required. No employees or outside parties will suffer due to adhering to this policy, nor will doing so impact their employment or any business relationships with GamesCodeSale.
Who Is Covered by this Policy?
This policy applies to all businesses the GamesCodeSale owns or controls globally. The expectations outlined in this policy and those included in our Code of Conduct or Code of Ethics must be followed by all GamesCodeSale employees and third parties.
What's the Risk?
The integrity, stability, and reputation of GamesCodeSale may be compromised by AML law violations, which also may result in civil and/or criminal prosecution of GamesCodeSale and/or its employees. Additionally, it can impair business dealings and connections and limit how the GamesCodeSale runs its operations.
What Is Money Laundering and Terrorist Financing?
Transacting in money or other 'clean' assets after having obtained them illegally is known as money laundering. There is no apparent connection between clean money or assets and any illicit behavior. Money laundering is done to hide the source of the funds. Money that is used to finance terrorism, regardless of how it was acquired, is also included in money laundering.
The following actions are prohibited by this policy because they are regarded as money laundering:
- the conversion or transfer of property (including money), with knowledge or reasonable suspicion that the property is the result of criminal activity or another specific type of unlawful activity, with the intent to conceal or otherwise disguise the source of the property or to help any individual involved in the commission of such activity avoid legal repercussions;
- carrying out a financial transaction involving illegal goods;
- hiding or disguising information about the true nature, source, location, disposition, movement, rights regarding, ownership, or control of illicit property;
- the acquisition, possession or use of criminal property;
- advocating the conduct of illegal activities; participating in, joining in, attempting to commit, and encouraging, assisting, or facilitating the commission of any of the above-mentioned offenses;
- regardless of the location where the underlying criminal activity occurred, property can be considered criminal property if it results from any criminal behavior.
The term "terrorist financing" refers to a variety of actions whose primary goal is to financially support terrorist activities. In contrast to the phenomenon of money laundering, terrorist funding is concerned with the use of the money and not the source of the funds. It may not even entail the proceeds of illegal activity.
Warning Signs
It might be challenging to identify money laundering and terrorism financing because they are illegal actions. However, there are indicators that can help determine whether there is a chance that money laundering or financing for terrorism has taken place or may take place.
Warning indicators that should be reported include, for instance:
- A client refuses to supply the necessary information or provides information that is incomplete, misleading, or questionable;
- Requests to pay in cash;
- Payments to or from organizations or individuals that don't seem to have any logical or visible connection to the consumer or transaction;
- Receipts of multiple negotiable instruments to pay a single invoice;
- Payments to or from countries considered high risk for money laundering or terrorist financing;
- Payments from countries unrelated to the transaction or not logical for the customer;
- Overpayments followed by directions to refund a payment, especially if requested to send the payment to another company or person.
The list above is meant to be incomplete. Per this policy, any departure from a standard business procedure should prompt an investigation.
Responsibility for Compliance
Since GamesCodeSale works internationally, (senior) management is in charge of putting policies and processes in place to abide by AML requirements. In order to prevent, identify, and respond to (suspected) money laundering and terrorism financing, several procedures and controls have been put in place.
This policy must be read and followed by all employees and other parties. Additionally, they must be able to recognize any red flags that may appear in their daily operations and report any potential AML compliance issues to the department manager or directly to the CSR Department of GamesCodeSale without informing the parties to the transaction. They must also refrain from acting before receiving advice and/or instructions.
Due Diligence and Record-Keeping
Every new game distribution partnership that GamesCodeSale enters into is the subject of due diligence. Existing game distribution ties will also be examined, as appropriate, to see whether there are any obstacles to maintaining them. The proper screening levels and forms will depend on a number of things.
In close collaboration with department managers, the finance department must periodically assess existing game distribution ties. The CSR Department should be informed immediately if there is any suspicion or indication that money laundering or terrorist funding may occur. They will then advise and/or provide directions on what to do.
Records must be able to be presented as proof of due diligence and monitoring of new and existing business ties in order to support any investigation (internal or external). As a result, the Finance Department and department managers must keep track of their attempts to adhere to this policy as well as any further guidance and instructions given to them by GamesCodeSale.
Non-Compliance and Sanctions
Any director or worker who disobeys this policy may face appropriate disciplinary action, up to and including termination. Any violation of this policy by a third party will also give GamesCodeSale cause to reevaluate and possibly cancel the business relationship.
The actions taken by GamesCodeSale are separate from any penalties that may be imposed by the appropriate authorities in the event that AML rules are broken.
Questions?
Please get in touch with GamesCodeSale Customer Support at [email protected] if you have any questions about this policy or want to voice a concern.
This anti-money laundering policy, our practices, and internal audits are intended to guarantee that GamesCodeSale complies with all relevant laws and regulations on anti-money laundering and terrorist financing. It will be reviewed and updated on a regular basis to ensure that it remains relevant and functional.