MINDLINK GAMES INC. ANTI-MONEY LAUNDERING (AML) and COMBATING FINANCIAL TERRORISM (CBT) COMPLIANCE PROGRAM

1. Introduction

1.1 Purpose
This document establishes the Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Compliance Program (the “Program”) for Mindlink Games (the “Company”). The Program is designed to ensure full compliance with applicable laws, regulations, and international standards governing AML and CFT activities. The Company is committed to preventing its platforms and services from being exploited for money laundering, terrorism financing, or any other illicit activities.

1.2 Scope
This Program applies to all officers, directors, employees, contractors, and third-party affiliates of the Company (collectively referred to as “Personnel”). All Personnel are required to adhere strictly to the policies, procedures, and guidelines set forth in this Program.

2. Regulatory Framework

2.1 Philippine Regulatory Requirements
The Company shall comply with all relevant Philippine laws and regulations, including but not limited to:

  • Republic Act No. 9160 (Anti-Money Laundering Act of 2001), as amended by subsequent laws, including Republic Act No. 9194, Republic Act No. 10167, and Republic Act No. 10365.
  • Republic Act No. 9372 (Human Security Act of 2007) and Republic Act No. 11479 (Anti-Terrorism Act of 2020).
  • Bangko Sentral ng Pilipinas (BSP) Circular No. 950, which prescribes rules and regulations on AML/CFT.

2.2 International Standards
The Company shall also ensure compliance with relevant international standards and best practices, including:

  • Financial Action Task Force (FATF) Recommendations.
  • United Nations Security Council Resolutions (UNSCRs) related to terrorism financing.
  • Wolfsberg Group Principles for AML.

3. Risk Assessment

3.1 Identification of Risk Areas
The Company shall conduct a comprehensive risk assessment to identify potential vulnerabilities in its operations. Specific areas of concern include:

  • In-game currency transactions: Risks associated with the use and transfer of virtual currencies within the platform.
  • Cross-border transactions: Risks inherent in international financial transactions.
  • User anonymity: Potential misuse of anonymity features by bad actors.
  • Third-party payment systems: Risks from integration with external payment processors.

3.2 Mitigation Measures
Appropriate controls shall be implemented to mitigate identified risks, including but not limited to:

  • Monitoring large or unusual transactions: Implementation of automated systems to detect and flag suspicious activities.
  • Regular risk assessments: Ongoing evaluations to adapt to emerging threats and changing business practices.

4. Customer Due Diligence (CDD)

4.1 Customer Identification and Verification
The Company shall implement stringent Customer Due Diligence (CDD) procedures, including:

  • Identity verification: Collection of necessary identification documents and information during user registration, particularly for transactions exceeding specified thresholds.
  • Use of digital verification tools: Deployment of electronic identity verification systems to ensure the accuracy and authenticity of user information.

4.2 Ongoing Monitoring
The Company shall conduct continuous monitoring of customer activities and transactions to identify and address suspicious behavior promptly. This includes:

  • Transaction review: Regular analysis of user transactions to detect patterns indicative of money laundering or terrorist financing.
  • Customer profile updates: Periodic review and updating of customer information to ensure ongoing compliance.

5. Transaction Monitoring and Reporting

5.1 Automated Monitoring Systems
The Company shall deploy robust automated systems to monitor transactions in real-time, capable of detecting and flagging activities that may suggest money laundering or terrorism financing.

5.2 Suspicious Transaction Reporting (STR)
All Personnel are obligated to report suspicious transactions to the designated Compliance Officer. The Compliance Officer shall ensure that such reports are filed with the Anti-Money Laundering Council (AMLC) in accordance with Republic Act No. 9160 and other relevant regulations.

5.3 Record Keeping
The Company shall maintain comprehensive records of all transactions and CDD information for a minimum period of five (5) years, as required by law.

6. Training and Awareness

6.1 Training Programs
The Company shall establish mandatory AML/CFT training programs for all Personnel. These programs shall cover:

  • Legal obligations: Detailed understanding of relevant laws and regulations.
  • Internal policies: Familiarity with the Company’s AML/CFT policies and procedures.

6.2 Ongoing Education
The Company shall provide continuous education to ensure that Personnel remain informed about evolving threats and regulatory changes.

7. Third-Party Due Diligence
7.1 Third-Party and Vendor Compliance
The Company shall perform rigorous due diligence on all third-party vendors and partners, particularly those involved in payment processing. Contracts with third parties shall include provisions requiring adherence to the Company’s AML/CFT policies.

7.2 Compliance Audits
The Company reserves the right to audit third-party partners for compliance with AML/CFT requirements. Non-compliance may result in termination of the partnership or contractual relationship.

8. Internal Controls and Governance

8.1 Designation of Compliance Officer
The Company shall appoint a Compliance Officer with the requisite authority and resources to oversee the implementation and enforcement of this Program.

8.2 Internal Audits
The Company shall conduct regular internal audits to assess the effectiveness of its AML/CFT controls and procedures. Findings shall be reported to senior management and, where necessary, to the board of directors.

9. Reporting and Communication

9.1 Internal Reporting Mechanisms
The Company shall establish secure and confidential channels for Personnel to report potential non-compliance or suspicious activities. These channels shall ensure anonymity and protection against retaliation.

9.2 External Reporting Obligations
The Company shall fulfill all external reporting obligations, including the filing of Suspicious Transaction Reports (STRs) with the AMLC, in accordance with applicable laws and regulations.

9.3 Communication Strategy
The Company shall maintain regular communication with all Personnel regarding updates to this Program and any changes in regulatory requirements.

10. Continuous Improvement

10.1 Program Evaluation
The Company shall regularly evaluate and update this Program to ensure it remains effective and responsive to new risks, technological advancements, and changes in the regulatory landscape.

10.2 Feedback Mechanisms
The Company encourages feedback from Personnel and stakeholders on the implementation and effectiveness of this Program, which shall be used to inform ongoing improvements.

Conclusion

The Mindlink Games Compliance Program is a comprehensive framework designed to ensure strict adherence to AML/CFT laws and international standards. By implementing the policies and procedures outlined herein, the Company commits to fostering a culture of compliance and safeguarding against financial crimes.