Version: 1.8
Date of Last Update: March 14, 2025
1. PURPOSE & SCOPE
1.1. Purpose
The purpose of this Bank Secrecy Act (“BSA”) Policy is to outline how EZ Sweeps, Inc. (hereinafter, “EZ Sweeps,” “Company,” “we,” “us,” or “our”) endeavors to comply, where applicable, with the Bank Secrecy Act and its implementing regulations. Our efforts aim to prevent, detect, and report potential money laundering, terrorist financing, and other criminal financial activities.
1.2. Scope
Although EZ Sweeps functions primarily as a social casino and sweepstakes platform, certain transactions (e.g., Gold Coin purchases, Prize redemptions) may nonetheless attract regulatory scrutiny. This BSA Policy defines the fundamental compliance measures we employ, in conjunction with our AML Policy and KYC Policy.
2. OVERVIEW OF THE BSA
2.1. Legislative Background
The Bank Secrecy Act (BSA), codified at 31 U.S.C. 5311 et seq., along with 31 C.F.R. Chapter X, requires financial institutions and/or money services businesses (MSBs) to:
Prevent criminal misuse of their services,
Detect and report suspicious transactions, and
Maintain certain recordkeeping and reporting obligations.
2.2. Application to EZ Sweeps
While we do not engage in bank-like deposit-taking or traditional money transfers, we adhere to a risk-based approach aligned with BSA principles to mitigate any improper usage of our Platform for illicit activities. Should a federal or state regulator deem us an MSB or require licensing, we shall comply accordingly.
3. CORE ELEMENTS OF OUR BSA COMPLIANCE
Our BSA compliance framework at EZ Sweeps is grounded in these key pillars:
3.1. A Designated BSA Compliance Officer
We designate a BSA/AML compliance officer responsible for shaping strategy, overseeing staff training, monitoring suspicious activity, and maintaining necessary records. This officer collaborates with senior management to ensure adequate resources and authority.
3.2. Written Policies and Procedures
This Policy, combined with our AML Policy, captures the operational guidelines, detection standards, and reporting obligations required under BSA regulations.
3.3. Employee Training
Team members performing duties in customer support, finance, or compliance undergo annual or periodic training on BSA fundamentals, identifying suspect behavior, and the proper escalation process.
3.4. Independent Testing/Review
Our BSA procedures undergo independent (internal or external) testing according to our risk assessment schedule, ensuring adequacy and effectiveness.
3.5. Risk-Based Customer Due Diligence (CDD)
Per our KYC Policy, we validate player identities and assign a risk rating based on transaction patterns. Where circumstances dictate (e.g., high-value or suspicious behavior), we apply enhanced due diligence measures.
4. CUSTOMER IDENTIFICATION & DUE DILIGENCE
4.1. Basic KYC Procedures
All users must provide personal data (name, address, date of birth) and pass identity checks to create or maintain an account, in line with our KYC Policy. We verify user accounts prior to significant Gold Coin purchases or Prize redemptions beyond specified thresholds.
4.2. Risk Assessment
We categorize players (or transactions) as low, medium, or high risk, driven by factors such as:
Transaction frequency or volume,
Geographical considerations (e.g., FATF-listed regions), and
Patterns suggestive of structuring or suspicious activity.
4.3. Source of Funds
Consistent with our AML Policy, we may request SOF (Source of Funds) documentation if a player shows high-volume or repeated transactions. Failure to comply may yield account suspension.
5. SUSPICIOUS ACTIVITY & REPORTING
5.1. Identification of Suspicious Transactions
We monitor logs of Gold Coin acquisitions and Prize disbursements for potential red flags, such as:
Repeated or unusually large purchases,
Mismatched or invalid personal details,
Multiple accounts or circumvention attempts,
Structured deposits/withdrawals designed to avoid detection thresholds.
5.2. Suspicious Activity Reports (SARs)
Where we detect potential money laundering, fraud, or terrorist financing, we may file Suspicious Activity Reports (SARs) with FinCEN or relevant regulatory bodies.
5.3. Confidentiality
All SARs and compliance investigations remain strictly confidential, undisclosed to the implicated users or external parties unless legally obligated or required by authorities.
6. RECORDKEEPING & RETENTION
6.1. BSA Record Retention
We store data on player identification, transaction details, and suspicious activity for at least five (5) years after the relevant date or the close of the customer relationship—whichever is longer. Such records may include:
KYC documents,
Transaction logs, and
SOF or compliance-related files.
6.2. Confidential Storage
Data is maintained in secure environments with role-based access privileges. We comply with our Privacy Policy and data protection standards to shield personal data against unauthorized disclosure.
7. TRAINING & INDEPENDENT REVIEW
7.1. Staff Training
Employees handling:
Customer support,
Account/Transaction reviews,
Compliance duties,
must regularly train on BSA detection methods, suspicious transaction escalation, and how to coordinate with our BSA Compliance Officer.
7.2. Independent Testing
We conduct periodic internal or external audits to confirm:
The effectiveness of suspicious activity procedures,
Recordkeeping conformance,
Implementation of recommended improvements following prior audits or new guidance.
8. ENFORCEMENT & PENALTIES
8.1. Player Non-Compliance
If a user refuses or fails to comply with BSA-related requests (e.g., verifying ID or providing requested documents), we may suspend or terminate their account, forfeit relevant promotional items, and, if necessary, alert authorities.
8.2. Employee Disciplinary Measures
Employees who disregard or violate this Policy face corrective action up to and including termination, subject to the severity and intent of the infraction.
8.3. Regulatory Violations
Any non-compliance with BSA requirements can expose both EZ Sweeps and individuals to possible civil or criminal penalties. Compliance is, therefore, mandatory for all.
9. GOVERNANCE & CHANGES
9.1. Governing Authority
Our designated BSA Compliance Officer administers this Policy. Senior management and/or the Board of Directors ensure adequate resources to fulfill BSA obligations.
9.2. Policy Amendments
We reserve the right to update or revise this BSA Policy at any time based on legislative or regulatory developments, as well as operational shifts. Material changes are documented and shared with relevant personnel.
9.3. Effective Date
This version is effective March 14, 2025, superseding prior BSA-related statements or guidelines.
10. CONTACT & ACKNOWLEDGMENT
For questions or concerns about this Policy—or to report suspected BSA violations—please contact:
EZ Sweeps, Inc.
500 Shatto Pl, Suite 420
Los Angeles, CA 90020
Email: [email protected]
Phone: (213) 263-9898
By transacting on or through our Platform, you recognize your awareness of this BSA Policy and agree to cooperate with our compliance measures.
End of BSA Policy.
(© 2025 EZ Sweeps, Inc. All rights reserved.)
