Last Updated: 12/10/2026

This Anti-Money Laundering Policy (the "Policy") describes the measures used by Skill Forge IO LTD ("Company," "we," "us," or "our") to identify, prevent, monitor, and respond to money laundering, terrorist financing, fraud, payment abuse, sanctions breaches, and other financial crime in connection with the SkillForge mobile application and related services (collectively, the "Services").

This Policy applies to the operation of the Services in Great Britain (England, Scotland and Wales) and should be read alongside our Terms of Use, Deposits and Withdrawals Policy, and Privacy Policy.

1. General Principles

1.1: The Services allow eligible Users to deposit real money and participate in skill-based competitions against other Users for the opportunity to receive cash Winnings.

1.2: Deposited Funds are intended solely for participation in eligible skill-based competitions and are not ordinarily withdrawable. Only eligible Winnings earned through valid competitions may be withdrawn, subject to identity verification, fraud prevention, payment verification, and other applicable checks.

1.3: The Company does not permit the Services to be used for money laundering, terrorist financing, fraud, payment abuse, sanctions evasion, collusion, deliberate transfer of value between Users, or any other unlawful financial activity.

1.4: The Company maintains financial crime controls designed to reflect the nature, size, and risk profile of the Services and may update those controls where reasonably necessary.

1.5: The Company may also apply additional requirements imposed by its payment processors, banking partners, identity verification providers, fraud prevention providers, or other authorised service providers.

2. Legal and Regulatory Approach

2.1: The Company will comply with applicable laws and legal obligations relating to money laundering, terrorist financing, fraud, sanctions, and financial crime.

2.2: Relevant legislation may include, where applicable:

• The Proceeds of Crime Act 2002
• The Terrorism Act 2000
• The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, as amended
• The Sanctions and Anti-Money Laundering Act 2018
• Applicable UK financial sanctions requirements

2.3: SkillForgeIO operates skill-based competitions and does not offer gambling, betting, lotteries, or games of chance as described in our Terms of Use.

2.4: Nothing in this Policy is intended to state that the Company is subject to a specific regulatory regime where that regime does not legally apply.

2.5: Where specific anti-money laundering or financial crime obligations apply to the Company, the Company will comply with those obligations. The Company may also voluntarily apply similar controls where reasonably necessary for financial crime prevention or payment-provider requirements.

3. Customer Verification

3.1: The Company may require Users to complete identity, age, address, payment ownership, or other verification checks where reasonably necessary for legal, regulatory, security, fraud prevention, payment, or eligibility purposes.

3.2: Information used for verification may include:

• Full legal name
• Date of birth
• Residential address
• Email address
• Government-issued identification
• Identity or facial verification information
• Payment information
• Device information
• Geographic location information

3.3: The Company may use authorised third-party providers to perform identity, age, document, fraud prevention, sanctions, or other verification checks.

3.4: A User who cannot successfully complete required verification may have access to deposits, paid competitions, withdrawals, or other account functionality restricted.

4. Age and Location Verification

4.1: The Services are strictly intended for individuals aged eighteen (18) years or older.

4.2: Paid competitions are currently available only to eligible Users physically located in Great Britain (England, Scotland and Wales).

4.3: The Company may use device information, network information, geolocation data, or other technical information to verify a User's location.

4.4: Users must not use VPNs, proxies, GPS spoofing tools, location manipulation software, or other methods intended to conceal, falsify, or misrepresent their physical location.

4.5: Where a User's age, identity, or location cannot be reliably verified, the Company may restrict or refuse access to paid competitions or other relevant Services.

5. Payment and Withdrawal Controls

5.1: Deposited Funds are intended solely for participation in eligible skill-based competitions.

5.2: Deposited Funds are not ordinarily directly withdrawable except where required by applicable law.

5.3: Only eligible Winnings earned through participation in valid skill-based competitions may ordinarily be withdrawn.

5.4: Funds returned following a cancelled, voided, interrupted, or refunded competition do not automatically become Winnings and will generally retain their previous balance classification.

5.5: Withdrawals may be subject to identity verification, account ownership verification, payment verification, fraud prevention checks, account reviews, and other checks reasonably required by the Company or its payment providers.

5.6: The Company will require the destination bank account, payment account, or other supported withdrawal method to be registered in the same name as the verified User.

5.7: The Company may delay, restrict, or temporarily suspend a transaction where reasonably necessary to investigate suspected fraud, money laundering, collusion, payment abuse, chargebacks, account misuse, or other suspicious activity.

6. Ongoing Monitoring

6.1: The Company may monitor User account, transaction, competition, and payment activity throughout the User's relationship with the Services.

6.2: Monitoring may include review of:

• Deposits
• Withdrawals
• Competition entries
• Competition results
• Winnings
• Refunds
• Chargebacks
• Failed or reversed payments
• Payment methods
• Gameplay behaviour
• Account history
• Devices
• Geographic information
• Links between Users or accounts

6.3: Monitoring may be automated, manual, or a combination of both.

6.4: The Company may carry out additional reviews where activity appears unusual, inconsistent with previous User behaviour, or otherwise presents an increased financial crime risk.

7. Suspicious Activity

7.1: Activity that may result in further investigation includes, but is not limited to:

• Repeated or unusually high-value deposits
• Repeated failed, reversed, or disputed payments
• Excessive chargebacks
• Use of multiple payment methods without reasonable explanation
• Payment methods that appear to belong to another person
• Multiple accounts linked to the same User, payment method, device, or identity
• Attempts to avoid transaction or verification limits
• Significant or unexplained changes in transaction behaviour
• False, inconsistent, or suspicious identity information
• Unusual geolocation activity
• Repeated competitions between the same Users
• Suspicious patterns of one User repeatedly losing to another
• Deliberately poor gameplay inconsistent with previous performance
• Suspicious changes to withdrawal information
• Attempts to withdraw following unusual account activity
• Refusal to provide reasonably requested verification information

7.2: The presence of one or more indicators does not automatically mean that money laundering, fraud, or other unlawful activity has occurred.

7.3: The Company may review the relevant account, transaction, gameplay, payment, competition, device, location, or other available information before determining whether further action is required.

8. Collusion and Linked Accounts

8.1: Users are matched into competitions automatically through the Company's backend matchmaking system based on relevant skill-rating and competition criteria. Users cannot directly select or nominate another User as their opponent in a 1v1, and Arena competition.

8.2: This matchmaking structure reduces the ability of Users to intentionally arrange competitions with specific individuals for the purpose of transferring financial value.

8.3: The Company nevertheless monitors for possible collusion, linked accounts, account sharing, deliberate manipulation of gameplay, or attempts to influence the matchmaking process.

8.4: Relevant indicators may include:

• Multiple accounts controlled by the same person
• Accounts sharing payment information, devices, or identity information
• Attempts to manipulate skill ratings or matchmaking
• Unusual gameplay patterns inconsistent with a User's historical performance
• Coordinated account activity
• Evidence that another person is playing on behalf of a User
• Other activity suggesting that genuine independent competition is not taking place

8.5: Where collusion, account sharing, deliberate manipulation, or other prohibited activity is reasonably suspected, the Company may delay competition results, Winnings, or withdrawals while the matter is investigated.

8.6: Where a material violation is confirmed, the Company may take proportionate action in accordance with the Terms of Use and applicable law.

9. Enhanced Due Diligence

9.1: The Company may conduct additional verification or Enhanced Due Diligence where a User or transaction presents an increased financial crime risk.

9.2: Additional checks may include:

• Re-verification of identity
• Additional proof of address
• Payment method ownership verification
• Review of linked accounts
• Additional transaction monitoring
• Review of gameplay and competition history
• Review of devices, and geolocation information

9.3: Failure to provide reasonably requested information may result in deposits, competitions, withdrawals, or other account functionality being restricted.

10. Suspicious Activity Reporting

10.1: Any director, employee, contractor, or other authorised person who identifies activity that may reasonably relate to money laundering, terrorist financing, sanctions evasion, fraud, or other serious financial crime must escalate the matter internally to the person responsible for compliance.

10.2: The Company will review the available information and determine whether further investigation or external reporting is required.

10.3: Where required or appropriate under applicable law, the Company may submit a Suspicious Activity Report ("SAR") or other disclosure to the UK Financial Intelligence Unit within the National Crime Agency or another appropriate authority.

10.4: Information relating to suspicious activity investigations and reports will be treated as confidential.

10.5: The Company will not inform a User that a Suspicious Activity Report has been submitted or that a related investigation is taking place where disclosure is prohibited by law or may prejudice an investigation.

11. Account Reviews and Restrictions

11.1: Where suspicious activity is identified, the Company may temporarily restrict account functionality while an investigation is conducted.

11.2: Restrictions may include:

• Preventing further deposits
• Restricting paid competition entry
• Holding or delaying Winnings
• Delaying or suspending withdrawals
• Requesting additional identity or payment information
• Requiring additional verification
• Reviewing linked accounts
• Reviewing gameplay or competition history

11.3: The Company may also contact its payment processors, identity verification providers, banking partners, fraud prevention providers, or other relevant third parties where reasonably necessary to investigate suspicious activity.

11.4: Any action taken will be limited to what the Company reasonably considers necessary to protect Users, the Services, payment systems, and the integrity of SkillForgeIO competitions, subject to applicable law.

12. Record Keeping

12.1: The Company may retain appropriate records relating to financial crime prevention and investigations.

12.2: Records may include:

• Identity verification records
• Transaction records
• Deposit and withdrawal history
• Competition activity
• Chargebacks and payment disputes
• Fraud prevention information
• Enhanced Due Diligence records
• Suspicious activity reporting records

12.3: Records will be retained for as long as reasonably necessary to comply with applicable legal, regulatory, financial, fraud prevention, accounting, security, and reporting requirements.

12.4: Personal information retained for financial crime prevention purposes will be processed in accordance with the Company's Privacy Policy and applicable data protection law.

13. Responsibility and Training

13.1: The directors of Skill Forge IO LTD are responsible for ensuring that appropriate financial crime controls are maintained.

13.3: Responsibilities may include:

• Reviewing suspicious activity
• Managing Enhanced Due Diligence
• Reviewing financial crime controls
• Liaising with payment and verification providers
• Determining whether external reporting is required
• Maintaining relevant records
• Escalating material financial crime concerns to the directors

13.4: Directors, employees, or contractors whose roles involve payments, User accounts, fraud prevention, withdrawals, or compliance may receive appropriate training relating to financial crime risks and internal procedures.

14. Third-Party Providers

14.1: The Company may rely on third-party providers for services including payment processing, banking, payouts, identity verification, age verification, geolocation, fraud prevention, sanctions screening, and other compliance functions.

14.2: Information provided by third-party providers may be used as part of the Company's financial crime monitoring and investigation processes.

14.3: The availability or operation of certain financial crime controls may depend on the systems and services provided by authorised third parties.

15. Modifications to This Policy

15.1: The Company may update this Policy from time to time to reflect changes to the Services, payment methods, financial crime risks, legal requirements, payment-provider requirements, security practices, or operational requirements.

15.2: This Policy will be reviewed periodically and following any material change to the Company's business model or financial crime risk profile.

15.3: The date at the top of this Policy will be updated when material revisions are made.

16. Contact Information

If you have questions regarding this Policy or financial crime controls used by the Company, please contact:

Email: support@skillforgeio.com

Company Name: Skill Forge IO LTD