KYC and AML Policy

1. Introduction

This KYC and AML Policy (hereinafter - the “Policy”) describes the identity verification, anti-money laundering, counter-fraud, sanctions screening, payout control, and compliance measures applied by SKYNEX LTD, a company registered in England and Wales under company number 16866353, with its registered office at 85 Great Portland Street, First Floor, London, England, W1W 7LT (hereinafter - the “Company”, “we”, “us”, or “our”).

This Policy applies to all users of the website https://elysiumskins.com (hereinafter - the “Service”).

The purpose of this Policy is to prevent and detect money laundering, terrorist financing, sanctions evasion, fraud, identity misuse, chargeback abuse, use of unauthorized payment instruments, and other unlawful or prohibited activities related to the use of the Service, including account registration, transactions, and payout requests.

This Policy forms an integral part of the Company’s Terms of Service.

2. Scope

This Policy applies to:

• all Users who register for, access, or use the Service;
• all accounts created on the Service;
• all transactions conducted through the Service;
• all payout and withdrawal requests;
• all verification procedures carried out before or after registration, during account use, upon payout request, or in connection with any compliance review.

The Company may apply verification and compliance controls before enabling payout functionality and at any other time where additional review is reasonably required.

3. Definitions

For the purposes of this Policy, the following definitions apply:

• AML - anti-money laundering measures designed to detect, prevent, and report suspicious, unlawful, or high-risk activity.
• KYC - know your customer procedures used to verify a User’s identity, assess risk, and maintain compliance controls.
• EDD - enhanced due diligence measures applied in higher-risk cases.
• User - any individual who accesses or uses the Service.
• Account - the User’s account on the Service.
• Proof of Identity - a valid government-issued identity document used to verify the User’s identity.
• Proof of Address - a document confirming the User’s residential address, issued within the last 3 months, unless otherwise accepted by the Company.
• PEP - politically exposed person.
• Sanctions - economic, trade, or financial sanctions, embargoes, restricted party measures, or similar restrictions administered by competent authorities.
• Payout - any withdrawal, transfer, or release of funds or value from the Service to the User through an approved payment method.
• PSP - payment service provider or other third-party partner used for payment or payout processing.
• Suspicious Activity - any activity that appears unusual, inconsistent, deceptive, fraudulent, unlawful, high-risk, or indicative of possible money laundering, fraud, sanctions evasion, or other abuse.

4. Risk-Based Approach

The Company applies a risk-based approach to KYC and AML compliance. This means that the nature, timing, and extent of verification, monitoring, screening, and control measures may vary depending on the risk level associated with a User, account, transaction, payout request, payment method, geographic location, or behavior pattern.

Factors that may increase risk include, without limitation:

• inconsistent, incomplete, or suspicious account information;
• multiple failed verification attempts;
• unusual transaction or payout behavior;
• frequent changes in payout details;
• suspected use of proxies, VPNs, anonymization tools, or suspicious devices;
• activity connected with restricted or high-risk jurisdictions;
• sanctions or PEP indicators;
• fraud indicators, chargeback history, or payment disputes;
• use of payment methods or documents that do not appear to belong to the User;
• any conduct suggesting account misuse, identity misuse, or circumvention of Company controls.

Where a higher level of risk is identified, the Company may apply additional checks, request more information or documents, delay review, restrict account functionality, or refuse a payout.

5. Customer Identification (KYC)

To access payout functionality, the User must complete KYC verification to the satisfaction of the Company.

As part of KYC verification, the Company may request and review:

6. Verification Statuses and Review Time

A User’s verification request may be assigned one of the following statuses:

• Pending - documents or information have been submitted and are under review;
• Approved - verification has been successfully completed;
• Rejected - verification has failed or the submitted materials were insufficient, invalid, inconsistent, or unacceptable.

The Company aims to review properly submitted KYC documents within up to 1 business day from the moment all required documents are received.

However, review may take longer in cases involving:

• enhanced due diligence;
• technical or manual review;
• additional document requests;
• third-party verification delays;
• high-risk or suspicious activity indicators.

The Company may request resubmission or additional documents at any time. Payout functionality is unavailable unless and until the User’s verification status is Approved.

7. Enhanced Due Diligence (EDD)

The Company may apply enhanced due diligence where required by law, regulation, PSP requirements, internal controls, or the Company’s risk assessment.

EDD may include:

• requesting additional identity or address documents;
• requesting source of funds or source of wealth information;
• requesting information regarding the nature and purpose of transactions;
• requesting proof of ownership of the payment method;
• conducting manual compliance review;
• carrying out additional sanctions, PEP, fraud, and adverse media screening.

EDD may be applied, for example, where:

• a User is associated with a high-risk jurisdiction;
• unusual transaction or payout patterns are detected;
• information or documents are inconsistent;
• a User appears to be a PEP or a sanctions match;
• fraud, identity misuse, or payment abuse is suspected;
• the payout request presents elevated legal, fraud, or compliance risk.

8. Sanctions and PEP Screening

The Company reserves the right to screen Users, transactions, payout details, payment methods, devices, and related information against:

• sanctions lists;
• restricted party lists;
• PEP databases;
• fraud prevention databases;
• watchlists and risk intelligence tools used by the Company or its partners.

If a potential sanctions, PEP, or adverse match is identified, the Company may:

• request additional documents or information;
• place the account or payout request under review;
• delay, suspend, or reject the payout;
• restrict or suspend account access;
• take any further action required or permitted by law.

The Company does not provide services where doing so would violate applicable sanctions, AML, fraud prevention, or regulatory requirements.

9. Transaction Monitoring

The Company may monitor account activity, transactions, and payout requests on an ongoing basis in order to identify suspicious, unlawful, abusive, or prohibited conduct.

Monitoring may include:

• review of account activity and transaction frequency;
• review of payout behavior and destination details;
• review of discrepancies between User information and verification documents;
• review of device, IP, geolocation, and technical risk indicators;
• review of repeated failed payments, reversals, disputes, or chargebacks;
• review of behavior suggesting third-party use of an account or payment method.

Monitoring may be carried out automatically, manually, or with the assistance of third-party service providers.

10. Suspicious Activity Handling

If the Company detects or reasonably suspects suspicious activity, it may, without prior notice and to the extent permitted by law:

• request additional documents, explanations, or declarations;
• delay, suspend, or cancel the review of a payout request;
• restrict or suspend certain account features;
• freeze or suspend the account;
• reject a transaction or payout;
• return funds to the User’s balance where appropriate and technically possible;
• terminate the User’s access to the Service;
• report the matter to PSPs, fraud prevention partners, or competent authorities where required or permitted.

The Company is not obliged to disclose the specific reasons, internal logic, or compliance triggers behind a suspicious activity review where doing so would be inappropriate, unlawful, or would undermine the effectiveness of compliance controls.

11. Payout Controls

Payouts are subject to strict compliance, fraud prevention, and operational controls.

A payout may only be processed where:

• the User has successfully completed KYC verification;
• the User’s verification status is Approved;
• the User has provided accurate and complete payout details;
• the payout method is supported and permitted;
• the payout request passes the Company’s compliance, fraud, and payment checks.

The Company reserves the right to:

• delay or reject any payout pending review;
• request additional documents before processing a payout;
• impose payout limits or restrictions;
• refuse payouts to restricted, unsupported, or high-risk destinations;
• require that payouts be sent only by methods approved by the Company or its PSPs.

Withdrawals are permitted only to payment cards or other payment instruments issued in the User’s own name. The name entered for the payout method must exactly match or reasonably correspond to the name shown in the User’s proof of identity and verification records.

If the name on the card or payout instrument does not match the verified identity of the User, the Company reserves the right to reject the payout request.

12. Prohibited Activities

Users must not use the Service, directly or indirectly, for any unlawful, deceptive, abusive, or prohibited purpose, including but not limited to:

• money laundering or attempted money laundering;
• terrorist financing;
• sanctions evasion;
• use of stolen, unauthorized, or unlawfully obtained payment methods;
• use of another person’s card, bank account, or payout credentials;
• identity misuse, impersonation, or account sharing;
• submission of forged, altered, stolen, misleading, or false documents;
• chargeback abuse or fictitious transaction activity;
• fraudulent, manipulative, or deceptive conduct;
• attempts to bypass payout, regional, verification, or compliance restrictions;
• use of the Service in connection with illegal proceeds or unlawful commercial schemes;
• any conduct that violates applicable law, card scheme rules, PSP requirements, or Company policies.

Any such activity may result in immediate account restriction, payout refusal, account suspension, account termination, and reporting where required or permitted.

13. Data Collection and Retention

For compliance, fraud prevention, payout control, audit, and dispute handling purposes, the Company may collect and retain:

• identity information;
• address and contact information;
• KYC documents;
• payment and payout details;
• transaction records;
• device and technical information;
• screening and monitoring results;
• compliance notes and internal review records;
• communications with the User.

The Company may retain KYC, AML, transaction, and compliance records for as long as necessary to comply with legal, regulatory, tax, fraud prevention, dispute resolution, audit, and operational obligations.

Unless a longer period is required or permitted by applicable law, such records may be retained for up to 5 years after the end of the User relationship, closure of the account, resolution of the relevant matter, or completion of the relevant review.

14. User Obligations

The User agrees to:

• provide accurate, complete, and current information;
• submit valid and authentic documents when requested;
• cooperate in a timely manner with compliance reviews;
• ensure that payout details are accurate and belong to the User;
• keep account information up to date;
• refrain from using the Service for prohibited or unlawful purposes.

Failure to comply with these obligations may result in verification failure, payout rejection, account restriction, suspension, or termination.

15. Company Rights

The Company reserves the right, at its sole discretion and to the extent permitted by law, to:

• request identity, address, payment method, or source of funds information;
• reject documents that do not satisfy verification requirements;
• delay, refuse, suspend, or reverse a payout where necessary for compliance or security reasons;
• restrict, suspend, or terminate accounts;
• apply additional review before enabling or processing payouts;
• cooperate with PSPs, fraud prevention vendors, regulators, and authorities;
• amend, update, or replace this Policy from time to time.

Nothing in this Policy obliges the Company to approve any User, document, account, transaction, or payout request.

16. Use of Third Parties

The Company may use third-party service providers to support:

• payment processing;
• identity verification;
• document authentication;
• fraud prevention;
• sanctions and PEP screening;
• transaction monitoring;
• secure document storage;
• technical infrastructure and compliance support.

Such service providers may process data on the Company’s behalf or, where applicable, under their own legal responsibilities in accordance with applicable law and contractual arrangements.

17. Privacy and Data Protection

Personal data processed under this Policy shall be handled in accordance with the Company’s Privacy Policy and applicable data protection laws, including, where applicable, the UK GDPR and EU GDPR.

The Company takes reasonable technical and organizational measures to protect personal data and compliance records against unauthorized access, misuse, loss, disclosure, destruction, or alteration. However, no system of electronic storage or transmission can be guaranteed to be completely secure.

18. Regulatory Cooperation

The Company reserves the right to cooperate with:

• law enforcement authorities;
• regulators;
• courts;
• PSPs;
• fraud prevention partners;
• competent public authorities and supervisory bodies,

where required or permitted by law, regulation, lawful request, card scheme requirements, PSP obligations, or legitimate compliance interests.

Such cooperation may include the disclosure of relevant account information, documents, transaction records, compliance findings, and other information as permitted or required by applicable law.

19. No Affiliation with Valve or Steam

The Company is not affiliated with, endorsed by, or sponsored by Valve Corporation or Steam.

All trademarks, game titles, logos, and game-related content belong to their respective owners. Any references to third-party games or platforms are used solely for identification and compatibility purposes.

20. Amendments to this Policy

The Company may amend, update, or revise this Policy at any time.

Any updated version will be published on the Service and will become effective upon publication unless otherwise stated. Continued use of the Service after publication of an updated version constitutes the User’s acknowledgment of the revised Policy. Users are responsible for reviewing the current version of this Policy periodically.

21. Contact Information