PLEASE READ THIS POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICES. IN ADDITION TO THIS POLICY, YOU MUST COMPLY AND BE BOUND BY THE POLICIES AND PROCEDURES OF THE PLATFORM AT ALL TIMES, AND ANY INSTANCE OF NON-COMPLIANCE WILL RESULT IN THE TERMINATION OF YOUR ACCOUNT ON THE PLATFORM, AND APPROPRIATE REPORTING OF THE CIRCUMSTANCES OF SUCH NON-COMPLIANCE AND SUCH TERMINATION TO THE RELEVANT STATUTORY AUTHORITIES.

This anti-money laundering and countering the financing of terrorism policy (“Policy”) is for FanCraze Technologies Inc. and its subsidiaries (“FanCraze”/ “we” / “our” / “us”, which term shall refer to and include its shareholders, subsidiaries and affiliated companies, directors, investors, employees, officers, representatives, affiliates, or other related parties). This Policy shall be read along with the terms of use, which are available at https://www.fancraze.com/terms-of-use (“Terms of Use”). Capitalized terms used in this Policy and not otherwise defined shall have the meaning ascribed to such term under the Terms of Use.

This Policy governs the access, interaction, and/or use by the user(“you” or “your”), a natural person, of application, website content, products, and all services related to monetary transactions on to the site https://www.fancraze.com as well as to any other media forms, media channels, or mobile websites, offered by FanCraze on the Platform (“Services”) made available by FanCraze through third-party service providers (“Collaborators”) for the purpose of buying, selling and withdrawing on the Platform.

IMPORTANT INFORMATION ABOUT PROCEDURES

To help fight and prevent the unlawful funding of terrorism and money laundering activities, relevant governments and applicable laws around the globe require all virtual asset service providers to obtain, verify, and record information that identifies each person who transacts on our platform.

By developing and maintaining this Anti-Money Laundering Program (the “AML Program”), FanCraze seeks to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (“BSA”), its implementing regulations, and Financial Crimes Enforcement Network (“FinCEN") regulations.

Money laundering means engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Typically, criminal proceeds are converted into monetary instruments or deposited into accounts at financial institutions; afterwards, they are transferred into other accounts or other financial institutions to further separate the money from its criminal origin; finally, the funds are reintroduced into the economy and used to purchase other assets. Money laundering usually involves fraudulent activities, such as insider trading, market manipulation, ponzi schemes, cyber crimes etc.

Terrorist financing means providing or collecting funds, directly or indirectly, unlawfully, and wilfully, with the intention that such funds be used, or with the knowledge that such funds are to be used, in full or in part, in order to carry out terrorist activities.

INTRODUCTION

At FanCraze, we are committed to conducting our businesses and operations in the most honest, integrated, and ethical manner. FanCraze strongly condemns all activities relating to terrorism, money laundering financial transactions, and all other unlawful activities. We provide our full cooperation and support to all relevant government and regulatory authorities to identify, monitor, or report any such transaction.

We have a zero-tolerance approach to money laundering, terrorism financing and all other unlawful activities. We are committed to acting professionally, transparently, and fairly with integrity in all our business dealings and relationships as well as implementing and enforcing effective systems to counter money laundering and terrorism financing.

This AML Program, together with other policies, procedures, and internal controls that we may implement, is designed to ensure compliance with applicable BSA regulations, FinCEN regulations and other applicable legislative requirements of the United States of America and other countries that FanCraze currently operates or will operate in. It shall be reviewed and updated annually. This Policy sets out the minimum standard that must be followed. Where local laws, regulations or rules impose a higher standard, that higher standard shall be followed.

What this means for you: When you transact with FanCraze, we, along with our Collaborators, will ask for your personal details including your name, address, date of birth, and other such information for proper verification of our customers. We may also ask for a copy of one of more of your Official Valid Documents (OVD) including but not limited to your driver’s license, government-issued identity card (including Aadhaar card or any other national identity card), passport, or other identifying documents to confirm your nationality and residence (“Personal Information”). Upon submitting such personal information, you confirm that such details are correct and updated as on the date of submission. In case of any change in such details submitted by you, you are obligated to communicate with us all such changes along with a relevant OVD supporting such change, at the earliest. 

Relationship: Your access and use of the Services constitute your agreement to be bound by this Policy. If you do not agree to this Policy, you must immediately stop accessing our platform or using our Services. FanCraze reserves the right to immediately terminate any Services with respect to you, or generally cease offering or deny access to the Services or any portion thereof, at any time for alleged, suspected, or actual violation of this Policy. Supplemental terms may apply to a certain part of the Services, such as policies for a particular event, activity, or promotion, and such supplemental terms will be disclosed to you in connection with the applicable Services. Supplemental terms are in addition to and shall be deemed a part of the terms of usage for the purposes of the applicable Services. Supplemental terms shall prevail over this Policy in the event of a conflict with respect to the applicable Services.

Amendment: FanCraze may amend the Policy from time to time. Amendments will be effective upon FanCraze posting of such updated Policy at this location or the amended policies or supplemental terms on the applicable Service or by sending an email to you. Your continued access or use of the Services after such amendments constitutes your consent to be bound by the Policy, as amended.

Operational Information Collection and Sharing: Based on your proposed activities on the FanCraze, including without limitation, (i) funding your account, (ii) details pertaining to transactions conducted through the Platform; (iii) completion of your KYC (as per the ‘Know Your Customer requirements set under statutory requirements), (iv) accessing of third party payment services (“Operational Information”), you may provide additional Personal Information, which may include without limitation, certain sensitive Personal Information. At all times, you agree to share the Operational Information, with such Collaborators, as may be required to adequately provide you with the Services. Any information and documentation you provide must be correct and up to date. FanCraze reserves the right to require additional information at any time to verify your identification and any further information that may be required to satisfy this Policy and applicable regulations. If we suspect that the information or documentation you have provided is incorrect, false, outdated or does not correspond to the conditions established in this Policy or you fail to pass the verification by your own initiative or otherwise, then in our sole discretion, we may either request you to provide the information or suspend your account till correct and up to date information and documents are provided.

Retention of Operational Information: You understand that all Operational Information may be required to be stored for statutory purposes with FanCraze and/or its Collaborators to help the relevant governments and statutory organizations fight the funding of terrorism and money laundering activities. Given the extremely sensitive nature of the Operational Information, you undertake that any information shared by you shall be true and accurate at all times, and any deviation from such accuracy and truthfulness of the Operational Information shall be intimated to FanCraze. FanCraze reserves the right to restrain you from conducting any activities on FanCraze based on the Operational Information at any time, without notice.

Data Collection, Privacy, and Usage: The policy for our collection and use of personal information in connection with the Services and FanCraze’s Privacy Policy is located at https://www.fancraze.com/privacy-policy.

FanCraze may additionally provide to a claim’s processor or an insurer any necessary information (including your contact information) if there is a complaint, dispute or conflict, which may include theft, involving you and a Collaborator (including our payments partners, etc.) and such information or data is necessary to resolve the complaint, dispute or conflict.

ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM (“AML/CFT”)

FanCraze and its Collaborators shall ensure that no transaction in which FanCraze is engaged shall be in non-compliance with jurisdictional AML/CFT-related applicable laws, play an active role in the identification and assessment of any potentially suspicious transactions, and ensure that FanCraze discharges its legal obligation to report suspicious transactions to concerned authorities.

FanCraze and Collaborators shall ensure that any AML/CFT- related violations by users that may implicate FanCraze shall be reported as soon as possible upon discovery.

KNOW YOUR CUSTOMER (“KYC”) COLLECTIONS

You shall be subject to KYC to successfully conduct transactions on the Platform. The requirement of KYC is in accordance with the applicable statutes and ‘you’, a customer is required to complete KYC if you wish to transact on the Platform or purchase and store any digital collectibles.

KYC is required prior to the onboarding of a new user, and shall be done on a regular basis, and when it is deemed appropriate. FanCraze may on a risk-basis, subject additional customers to KYC, or require Collaborators to conduct additional KYC on its behalf. Each such Collaborator will contract with FanCraze conforming to FanCraze’s requirements, statutory requirements, and this Policy.

KYC For Individuals: You must provide the following for completion of KYC: (i) full legal name; (ii) date of birth; (iii) nationality, (iv) residential address; and (v) identification number. This must be verified through documentation (tax filings or passport) or such other document as may be acceptable to FanCraze as per its internal policies and regulatory requirements.

Verification: Documentary verification is performed when you submit an identification document (“ID”), along with a “selfie” to evidence that you are the same individual as listed on the ID. The ID must be government issued, unexpired, list the holder’s nationality or residence, bear a photograph or similar safeguard, and show information in English. In case you fail to pass the verification procedure, FanCraze is obliged to cancel the Services following the Policy.Additionally, FanCraze may, on a risk basis, require a Collaborator to conduct additional KYC.

We shall perform a liveness check and face match wherein we conduct a biometric analysis of a customer’s facial movements and compare it with the photographs on the submitted documents. This is to ensure that a person is truly present and that the documents submitted belong to the person. We also use this information to perform a ‘known face search’ to determine whether a person’s face is duplicated or present on blacklists.

We shall perform verification of the email address and phone number provided by the customer to ensure their validity and that they belong to a real person. We shall authenticate the email address and phone number with a one-time code to ensure that the customer has access to their mailbox or can be reached at the provided phone number. We shall cross-validate the customer’s name, email address, IP address country and phone number country to check that the customer is not using a VPN service. We shall run a duplicate name search to check that different persons are not using the same email address or phone number.

If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, we shall not open a new account or, after considering the risks involved, consider closing any existing
account.

We use SumSub and Digio as our vendors to verify customer information. Based on the risk, and to the extent reasonable and practicable, FanCraze shall ensure that it has a reasonable belief that it knows the true identity of each of its customers by using risk-based procedures to verify and document the accuracy of the information it gets about its customers.

Appropriate documents for verifying the identity of customers include an unexpired government-issued identification evidencing nationality or residence and bearing a photograph
or similar safeguard, such as a driver’s license, national identification document, or passport,
showing such information.

Depending on the nature of the account and requested transactions, we may refuse to complete a transaction before we have verified the information. Upon determination of suspicious information that indicates possible money laundering, terrorist financing activity, or other suspicious activity, we shall, after internal consultation with the Anti-Money Laundering Program Compliance Lead (AMLCL), escalate this to relevant third parties including third party vendors.

Record Keeping: We shall document our verification, including identifying information provided by a customer, the methods used and results of such verification, and the resolution of any discrepancies identified in the verification process. We shall keep records containing a description of any document that we rely on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we shall retain documents that describe the methods and the results of any measures we took to verify the identity of a customer. We shall also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We shall retain records of all identification information for five years after the account has been closed.

PROHIBITIONS

Your activities may be prohibited, your account may be suspended, and Services may be restricted if FanCraze has knowledge or suspicion that you are involved in transactions related to:

• Weapons of any kind, including but not limited to firearms, ammunition, knives, explosives, or related accessories;
• Controlled substances, including but not limited to narcotics, prescription drugs, steroids, or related paraphernalia or accessories; 
• Prostitution;
• Unlawful gambling activities including but not limited to sports betting, casino games, horse racing, dog racing, lotteries, games of chance, sweepstakes, games of skill that may be classified as gambling (i.e., poker), or other activities that facilitate any of the foregoing;
• Money-laundering or terrorist financing;
• Any sort of Ponzi scheme, pyramid scheme, or multi- level marketing program;
• Goods or services that infringe or violate any copyright, trademark, or proprietary rights under the applicable law;
• Lottery contracts, layaway systems, or annuities; Counterfeit goods, including but not limited to fake or “novelty” IDs;
• Wash trading, front-running, insider trading, market manipulation or other forms of market-based fraud or deceit;
• Purchasing goods of any type from Tor hidden service markets or “Darknet” markets, or any other service or website that acts as a marketplace for illegal goods (even though such marketplace also sell legal goods); Transactions involving sanctioned parties, countries or coins; and
• Any other activity that is against the laws and regulations of countries in which FanCraze or its Collaborators operates.

You are prohibited from accessing our Services (and your IP address will be blocked by FanCraze or its Collaborators) if you are from one of the following countries/regions or any other country/region where Services cannot be provided by FanCraze due to any applicable regulation or sanctions:

USA - Sanctioned Country List

• Central African Republic
• Democratic Republic of the Congo
• Eritrea
• Iran
• Iraq
• Lebanon
• Libya
• Mali
• Myanmar
• North Korea
• Somalia
• South Sudan
• Sudan
• Syria
• Tunisia
• Venezuela
• Yemen
• Zimbabwe

OFAC - Sanctioned Country List

• Afghanistan
• Balkans
• Belarus
• Burundi
• Central African Republic
• Crimea Ukraine
• Cuba
• Democratic Republic of Congo
• Guinea-Bissau
• Iran
• Iraq
• Lebanon
• Libya
• Mali
• Myanmar
• Nicaragua
• North Korea
• Somalia
• Sudan and Darfur
• South Sudan
• Syria
• Syrian Arab Republic
• Ukraine
• Venezuela
• Yemen
• Zimbabwe

India - Restricted States

• Assam
• Odisha
• Nagaland
• Sikkim
• Meghalaya
• Andhra Pradesh
• Telangana

ADDITIONAL DOCUMENTS AND SCREENING

We may conduct due diligence prior to or after creating your account, requesting additional documents, and regularly screen you against the following sanctions list:

• Monetary Authority of Singapore;
• Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals (“SDN”) list;
• OFAC non-SDN lists;
• European Union sanctions lists; 
• FATF High-Risk Jurisdictions & FATF Jurisdictions under Increased Monitoring lists;
• DFAT Consolidated Sanction List (AU);
• United Nations sanctions lists; and
• UK Her Majesty’s Treasury sanctions lists.

We may further screen the transactions to and from your blockchain addresses against the sanctioned blockchain addresses released and identified either by (i) regulators and agencies across different jurisdictions; or (ii) our Collaborators. We may use a Collaborator and other third-party tools for such screening.

Your account may be put on freeze immediately upon (i) you operating from prohibited jurisdictions or upon discovery of the account being associated with sanctions lists specified above; (ii) usage of any virtual private networks to access Services from prohibited jurisdictions; (iii) any notice of suspicion of AML/CFT related or suspicious transactions received from Collaborators; (iv) pursuant to a court order, or a request from a regulator or a request from a Collaborator; (v) if FanCraze determines at its sole discretion that your account poses a security or legal risk as part of an internal or external investigation; or (vi) if FanCraze determines at its sole discretion that you reside in or are citizens or tax residents of any state, country, territory or other jurisdiction where participation in token sales would be illegal or otherwise in violation of any applicable law (“Frozen Account”).

Basis input from its Collaborators and other stakeholders, FanCraze shall for the Frozen Account, choose an appropriate course of action including (i) regulatory reporting; (ii) intimation to its Collaborators, and regulatory reporting by them, if required; or (iii) take such action as may be required under law, including permanently freezing the account pending completion.

Any questions on the Policy may be directed at:[email protected]. 

CUSTOMER DUE DILIGENCE RULE

We do not open or maintain accounts for legal entity customers and hence the customer due diligence rule does not apply.

ENHANCED DUE DILIGENCE 

We may inter alia in the following situations classify a customer as a high-risk customer and undertake enhanced due diligence procedures for such customers:

1. upon identification of a person or verification of submitted information, there are doubts as to the truthfulness of the submitted data, authenticity of the documents or identification of the beneficial owner;
2. the customer is from a high-risk country or the seat of the payment service provider of the customer is in a high-risk country;
3. the customer is from a country or territory or the seat of the payment service provider of the customer is in a country or territory that, according to credible sources such as mutual evaluations, reports or published follow-up reports, has not established effective AML/CFT systems that are in accordance with the recommendations of the Financial Action Task Force (FATF), or that is considered a low tax rate territory; and
4. any other situation where there is a higher risk of money laundering as defined by applicable laws and regulations.

For purposes of this policy, high risk countries refer to countries (other than the prohibited countries) which are identified by FanCraze from time to time. Such identification will inter alia be based on criteria including higher rate of identity fraud, credit card fraud, and high percentage of blockchain address sanctions. Such identification will be based on FanCraze’s customer data and customer behavior as well as overall industry trends and advice of FanCraze’s identity verification partner, payment gateway partners and blockchain monitoring partners.

The enhanced due diligence measures for customers in a high-risk third country may include one or several of the following:

1. obtaining additional information on the customer;
2. obtaining information on the source of funds and source of wealth of the customer.

We shall monitor account activity for unusual size, volume, pattern, or type of transactions, taking into account risk factors and red flags appropriate for our business (as enlisted below). The AMLCL will be responsible for this monitoring, will review any activity that the monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will notify this to relevant third parties.

TRAINING PROGRAMS

We shall develop ongoing employee training under the leadership of the AMLCL and senior management. Such training will occur on a periodical basis.

The training will include, at a minimum: 

1. how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; 
2. what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags for analysis and, where appropriate, notification and escalation to relevant third party including vendors); 
3. what employees' roles are in the firm's compliance efforts and how to perform them; 
4. FanCraze’s record retention policy; and 
5. the disciplinary consequences for non-compliance with this policy.

MONITORING EMPLOYEE CONDUCT AND ACCOUNTS

We will subject employee accounts to the same AML Program as customer accounts, under the supervision of the AMLCL. The AMLCL’s accounts will be reviewed by an official from the senior management.

CONFIDENTIAL REPORTING OF AML NON-COMPLIANCE

Employees are required to promptly report any potential violations of the firm’s AML Program to the AMLCL, unless the violations implicate the AMLCL, in which case the employee shall report such potential violation to Anshum Bhambri. Such reports will be confidential, and the employee will not suffer any retaliation for reporting the same.