Version: 1.8
Date of Last Update: March 14, 2025
1. PURPOSE & SCOPE
1.1. Objective
The purpose of this Anti-Money Laundering (“AML”) Policy is to outline the procedures by which EZ Sweeps, Inc. (“EZ Sweeps,” “we,” “us,” or “our”) detects, prevents, and reports any potential money laundering or terrorist financing activities, in line with our broader responsibilities under applicable AML/BSA regulations, FinCEN guidance, and state laws. This Policy also complements our KYC Policy, Terms & Conditions (T&C), and Official Social Casino Rules, ensuring a consistent, compliant approach across the entire Platform.
1.2. Policy Coverage
All levels of EZ Sweeps—management, employees, contractors, and appointed third-party agents—are required to follow this AML Policy. Similarly, all Players on our Platform must cooperate with AML measures, including transaction verifications or enhanced due diligence steps.
1.3. No Real-Money Wagering
While EZ Sweeps operates a social casino and sweepstakes model (no real-money gambling), certain prize redemptions, Gold Coin purchases, or promotional transactions may still create money-laundering risk points. This AML Policy addresses those risk areas accordingly.
2. DEFINITIONS
“Player” or “Customer”: An individual who creates an account and/or participates in any Game or feature on the Platform.
“Money Laundering”: The process by which proceeds from illegal activities are introduced into legitimate commerce, obscuring their origin.
“Terrorist Financing”: Providing funds for terrorist activity, often disguised via legitimate-appearing transactions.
“KYC Policy”: Our Know Your Customer procedures, ensuring we verify user identities and ownership of Payment Mediums.
“SOF Verification” (Source of Funds): Checks that may be requested under our KYC protocols if high-risk triggers arise.
3. RISK-BASED APPROACH
3.1. Assessment
EZ Sweeps adopts a risk-based approach by reviewing multiple risk factors, including:
Transaction Frequency & Volume: Unexpected large sums of Gold Coin purchases or multiple high-value promotional prize redemptions may raise suspicion.
Geographical Risk: Users from jurisdictions with elevated AML concerns or from FATF-blacklisted regions.
Behavioral Indicators: Patterns of creating multiple accounts, inconsistent personal details, repeated geolocation changes, etc.
3.2. Risk Tiers
Customers may be assigned tiers (e.g., Low, Medium, High) based on these risk factors. High-risk customers may be subject to additional checks or Enhanced Due Diligence (EDD).
4. AML PROCEDURES
4.1. Account Registration & KYC
All Players undergo basic KYC at account creation. Additional steps may apply (e.g., verifying government ID, date of birth, address) per our KYC Policy if certain triggers occur (e.g., suspicious activity, high-value purchases, or prize exchanges).
4.2. Source of Funds (SOF)
If user activity (e.g., repeated large purchases, suspicious redemption requests) warrants it, we will request (SOF) Source of Funds Verification, requiring players to provide bank statements, pay stubs, or other documentation. Failure to comply may result in account restrictions (see Section 8).
4.3. Enhanced Due Diligence (EDD)
For higher-risk accounts, we may require:
More robust identification checks (e.g., multiple government IDs).
Corroboration of personal details via credit bureau or public records.
Closer monitoring of payment behaviors, deposit/withdrawal patterns, or anomalies in location usage.
4.4. Ongoing Monitoring
We periodically monitor user accounts for shifts in risk profile. Unusual activity or attempts to circumvent daily transaction limits may prompt an immediate review.
5. SUSPICIOUS ACTIVITY DETECTION
5.1. Examples of Red Flags
Multiple Payment Methods: A single user adding and removing numerous credit cards in short time frames.
Structuring: Breaking down large amounts into smaller transactions to avoid suspicion.
Geolocation Discrepancies: Logging in from high-risk or embargoed countries or states where services are restricted.
Third-Party Use: Apparent usage by someone else on a single Customer Account, or references to a corporate account for personal purchases.
5.2. Real-Time Alerts
Our systems may automatically flag transactions that exceed certain thresholds or deviate from historical patterns. Staff are expected to investigate any alerts promptly.
5.3. User Communication
If suspicious activity is detected, we may contact the user, requesting explanations or documentation clarifying the nature of the transactions. Non-responsive or evasive behavior can lead to account freezing or closure.
6. REPORTING & FINCEN COMPLIANCE
6.1. Suspicious Activity Reports (SARs)
Where our investigations yield reasonable suspicion of money laundering, terrorist financing, or any criminal abuse of our Platform, we may file a Suspicious Activity Report (“SAR”) with FinCEN or the relevant authority, following U.S. federal law.
6.2. Privacy & Confidentiality
We do not disclose SAR filings to the subject user. In compliance with law, all SAR-related communications are kept confidential.
6.3. MSB & MTL Considerations
MSB Status: Generally, EZ Sweeps does not meet the definition of a Money Services Business under FinCEN guidelines, as we do not conduct direct currency exchange or money transmission for third parties. However, if certain prize redemption processes or states’ interpretations require it, we will seek the relevant Money Transmitter License (MTL).
State Discretion: We may suspend certain features in states requiring MTL if we cannot secure such a license in a timely manner.
7. TRAINING & OVERSIGHT
7.1. Staff Training
All relevant EZ Sweeps personnel who handle payments, KYC, user support, or compliance tasks are trained annually on:
Recognizing potential signs of money laundering or fraud.
Properly using detection systems, alerts, and internal reporting channels.
Respecting user privacy within the AML/BSA framework.
7.2. Compliance Officer
A designated AML Compliance Officer oversees day-to-day compliance, ensuring internal checks are performed and that suspicious activity escalates appropriately.
7.3. Policy Review & Updates
We review this AML Policy periodically (at least once per year) to confirm its effectiveness, making revisions as legal or operational changes require.
8. CONSEQUENCES OF NON-COMPLIANCE
8.1. User Non-Compliance
If a user refuses or neglects to provide identification or documents requested under this AML Policy:
The user’s account may be suspended or closed.
Unexchanged Prizes or pending Gold Coin purchases may be withheld.
Repeated or severe non-compliance can lead to permanent ban and possible reporting to law enforcement.
8.2. Internal Disciplinary Measures
Staff failing to follow AML procedures, or deliberately circumventing them, risk disciplinary actions, including termination of employment, depending on severity.
8.3. Legal Exposure
Violations of AML/BSA laws can entail serious legal consequences for both EZ Sweeps and offending individuals, including fines or criminal penalties.
9. RECORDKEEPING & DATA PROTECTION
9.1. Retention Period
In line with AML/BSA requirements, we store KYC, transaction, and suspicious activity records for at least five (5) years from the date of the record’s creation or last update.
9.2. Secure Storage
Data is stored in secure, access-controlled environments. Only authorized staff with a valid compliance-related reason can access AML records.
9.3. Privacy Compliance
Our Privacy Policy governs all user data, ensuring it is not used for unauthorized purposes. We only share or release personal data when lawfully required (e.g., subpoena, regulatory inquiry, etc.).
10. EFFECTIVE DATE & CONTACT
10.1. Effective Date
This AML Policy is effective February 7, 2025, and remains in force until superseded or updated. Any material changes will be posted on our Platform.
10.2. Contact Us
For questions on this AML Policy or to report suspicious matters, contact us at:
Email: [email protected]
Phone: (213) 263-9898
Address: EZ Sweeps, Inc., 500 Shatto Pl, Suite 420, Los Angeles, CA 90020
10.3. Acknowledgment
By creating or using an account with EZ Sweeps, you agree to cooperate with any AML-related requests and to abide by our Terms & Conditions, Official Social Casino Rules, KYC Policy, and this AML Policy.
End of AML Policy
(© 2025 EZ Sweeps, Inc. All rights reserved.)
