Version: 1.8
Date of Last Update: March 14, 2025
PURPOSE & SCOPE
1.1. Purpose
This Know Your Customer (KYC) Policy sets forth the procedures and responsibilities by which EZ Sweeps, Inc. (hereinafter, “EZ Sweeps,” “we,” “us,” or “our”) verifies and authenticates the identity of its customers and prospective customers. KYC measures enable us to ensure compliance with all relevant AML/BSA obligations, detect potential fraud, and maintain a secure, responsible environment as outlined in our Terms & Conditions (hereinafter “T&C”) and Official Social Casino Rules.
1.2. Scope
This Policy applies to any Player (i.e., individual user) seeking to create, maintain, or use a Customer Account on the EZ Sweeps platform (the “Platform”). All users must comply with this Policy as a condition to continued access or participation in both Standard Play (Social Casino) and Promotional Play (Sweepstakes) modes.
KEY OBJECTIVES
2.1. Identity Verification
We aim to verify the true identity of each Player to mitigate risks such as:
Fraudulent activity (e.g., stolen identities, unauthorized payments)
Money laundering or terrorist financing
Underage usage in jurisdictions with age restrictions
2.2. Compliance
We adhere to AML/BSA guidelines, along with all applicable state/federal laws, requiring effective, risk-based KYC procedures. Our compliance efforts also align with any relevant Money Transmitter License (MTL) considerations, MSB rules, and FinCEN guidance if they become applicable to certain transactions or Prize redemption processes.
2.3. Fair & Responsible Gaming
By verifying identities, we help protect responsible social gameplay and sweepstakes participation, ensuring participants meet location eligibility rules and minimum age requirements per our T&C and Official Rules.
CUSTOMER ACCOUNT REGISTRATION
3.1. Minimum Information Collected
At the time of account creation or thereafter, we may request:
Full Legal Name
Date of Birth (must be 18 or older, or the applicable age of majority)
Residential Address
Valid Email Address
Contact Phone Number (where required or for SMS verifications)
Location (state/province/country)
3.2. Identification Checks
We reserve the right to request additional proof of identity or address at any time, particularly before prize redemptions or in cases of suspicious activity. Acceptable documents may include, but are not limited to:
Government-issued Photo ID (driver’s license, passport, national ID card)
Bank Statements or Utility Bills confirming address
Credit Card or Payment Medium statements showing the name and last four digits
3.3. Age & Location Verification
Age Verification: We employ third-party or internal checks to ensure Players meet minimum age requirements.
Location Verification: We may use geolocation services or IP checks to confirm jurisdictional eligibility, as certain regions are excluded. Attempting to circumvent location restrictions violates our T&C and may result in suspension.
RISK-BASED APPROACH
4.1. Risk Levels
We evaluate user behavior and transactions to assign a risk level. Factors include:
High-Value Transactions: Significant Gold Coin purchases, frequent deposits, or sweepstakes redemptions over specified thresholds (e.g., US$2,000).
Geographic Risk: Users from jurisdictions with higher AML concerns or FATF blacklists.
Behavioral Red Flags: Multiple failed payment attempts, inconsistent personal details, frequent location changes, or bot-like usage patterns.
4.2. Enhanced Due Diligence (EDD)
For higher-risk scenarios, we may implement EDD, which can involve:
More detailed identity checks
Source of Funds (SOF) documentation (e.g., pay stubs, bank statements)
In-depth verification of Payment Medium ownership
4.3. Ongoing Monitoring
User accounts may be periodically reassessed for changes in risk level. Suspicious or unusual activity can trigger immediate review or partial restrictions until KYC processes are satisfactorily completed.
SOURCE OF FUNDS (SOF) VERIFICATION
5.1. Rationale
In accordance with the T&C and the SOF Verification approach, we may request documentation to confirm that a Player’s financial resources (used for Gold Coin purchases, etc.) are legitimate and free from illegal origins.
5.2. Documentation
Players may be asked to submit:
Recent Bank/Pay Statements
Proof of Earnings (e.g., salary slips)
Tax Returns or relevant financial documents
Failure to comply with an SOF request may result in account suspension or denial of Prize redemption until compliance is met.
5.3. Confidentiality
Any documents provided for SOF checks are protected in line with our Privacy Policy. They are reviewed by authorized staff solely for compliance purposes. We strive to keep them confidential except as required by law or in response to regulatory obligations.
DISCREPANCIES & FRAUD PREVENTION
6.1. Inconsistent Data
If identity or payment information fails to match the documents provided, we may:
Temporarily restrict account usage (e.g., block further purchases or prize redemptions)
Request additional documents or clarifications
Decline or close the account for suspected fraud if discrepancies remain unresolved
6.2. Reporting
In line with AML/BSA rules, we may submit Suspicious Activity Reports (SARs) to relevant authorities (e.g., FinCEN) if we determine there is sufficient reason to suspect illicit behavior.
6.3. Prohibited Conduct
Any attempt to use stolen IDs or payment methods, falsify personal information, or mask true location is a breach of the T&C and may lead to legal consequences and account termination.
DATA PRIVACY & RETENTION
7.1. Privacy
All personal data collected under this KYC Policy is handled according to EZ Sweeps’ Privacy Policy. We employ strict access controls, secure servers, and encryption where suitable.
7.2. Retention Period
We maintain KYC records as long as needed under legal or regulatory directives (e.g., AML/BSA standards). Typically, certain records may be retained for 5 years from account closure or from the date of the last transaction, whichever is later.
7.3. User Rights
Where permitted by local law, you may have rights to access, rectify, or request deletion of personal data. However, we may decline such requests if ongoing legal/regulatory obligations require continued retention (e.g., AML compliance).
NON-COMPLIANCE & CONSEQUENCES
8.1. Mandatory Cooperation
Refusal or failure to comply with any KYC procedures (e.g., not providing requested ID or ignoring SOF documentation requests) may result in immediate:
Account suspension or closure
Denial of Prize redemption or Gold Coin purchase transactions
Notification to appropriate regulatory bodies if illegal activity is suspected
8.2. Player’s Liability
You are responsible for ensuring all information provided is truthful and accurate. Any misrepresentation or breach of this KYC Policy (or the overarching T&C) can prompt legal and/or account-level consequences.
CONTACT & POLICY CHANGES
9.1. Contact Information
For any questions regarding this KYC Policy, you may contact us at:
Email: [email protected]
Phone: (213) 263-9898
Address: 500 Shatto Pl, Suite 420, Los Angeles, CA 90020
9.2. Policy Updates
EZ Sweeps reserves the right to update or revise this KYC Policy at any time. Material changes will be posted on our Platform. Continuing to use the Platform after updates constitutes acceptance of the revised Policy.
9.3. Effective Date
This Policy is in effect as of March 14, 2025 and remains so until replaced or superseded.
ACKNOWLEDGMENT
By creating or maintaining a Customer Account with EZ Sweeps, or by participating in any Games on our Platform, you confirm that you have read, understood, and agree to abide by this KYC Policy, in conjunction with our Terms & Conditions and Official Social Casino Rules.
End of KYC Policy.
© 2025 EZ Sweeps, Inc. All rights reserved.
