AML & KYC Compliance
Help us to run our company lawfully.
1. Company Business Model
Remake.gg OÜ (“ Remake.gg ” or the “ Company ”) is a company that operates an online platform at www.remake.gg for skill-based games. Our platform allows users to compete in games where the outcome is determined by their input and expertise, rather than chance (“ games of chance ”). We are committed to maintaining high standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance and have implemented robust processes to ensure compliance with relevant regulations. We currently serve users in over 230 countries worldwide, with the exception of the United States and Estonia.
To ensure the integrity of our platform and protect against illicit activity, Remake.gg OÜ has implemented a range of compliance measures. These include thorough onboarding and screening of our customers, as well as transaction monitoring systems to detect any potential issues. We are committed to maintaining the highest standards of compliance and work continuously to improve our processes.
2. Company Policy Statement
Remake.gg OÜ is a company that operates an online platform for skill-based games. While we are not a financial institution and are not subject to the same regulations as banks or other financial service providers, we are committed to preventing the use of our platform for any illegal activity. This includes prohibiting and rejecting the use of our products for any form of illicit activity, such as money laundering, terrorist financing, or trade sanctions violations. We are compliant with all applicable Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regulations in the European Union and Estonian jurisdiction, as well as national Anti-Money Laundering (AML) laws, regulations, and norms. We also regularly review and update our policies and procedures to ensure that we are in compliance with any changes in the law or industry standards, including those set by the Financial Action Task Force (FATF) and relevant eSports and gaming trade groups. We take our compliance obligations seriously and are committed to maintaining the highest standards to protect against illicit activity on our platform.
Remake.gg OÜ is committed to following global best practices to prevent the use of our products for illegal activities. Some of the measures we have in place to achieve this include:
- A written policy and procedures to prevent money laundering, terrorist financing, and trade sanctions violations, as well as controls to ensure compliance;
- The appointment of a compliance officer to oversee the implementation and enforcement of these policies and procedures;
- Ongoing education and training for relevant personnel on compliance matters;
- Regular reviews, monitoring, and maintenance of our compliance policy, procedures, and controls to ensure effectiveness;
The following defined terms are widely used in the industry:
Money Laundering: A process that involves disguising illegal proceeds as legitimate funds. It typically involves three steps:
Placement: Introducing illicit funds into the financial system through deposits or other means.
Layering: Separating illegal funds from their source through complex financial transactions, such as converting cash into securities or purchasing assets.
Integration: Using legitimate transactions to conceal illegal proceeds, allowing them to be reintegrated into normal use.
Suspicious Activity: Transactions that may be conducted by a user or non-user of an institution and which may indicate fraudulent or illegal intentions.
Sanctions: Actions taken by the international community to restrict or prohibit certain activities of a targeted individual or entity. Examples include: nuclear proliferation, human rights abuses, and terrorism.
4. Governance and Oversight
Remake.gg OÜ has appointed a Chief Compliance Officer (CCO) who is responsible for implementing and coordinating our AML (Anti-Money Laundering) policies and program. The CCO's responsibilities also include developing AML initiatives, collaborating with stakeholders to update our Anti-Money Laundering (AML) policy, evaluating new regulatory requirements, and investigating potentially suspicious or unusual activity. In addition, we provide Anti-Money Laundering (AML) training to all of our employees on a regular basis to ensure that everyone is aware of their compliance obligations.
5. Know Your Customer and Transaction Monitoring
Remake.gg will take all necessary steps to ensure compliance with relevant laws and regulations, including conducting appropriate due diligence on users and implementing ongoing monitoring measures. We will also strive to prevent any illegal or unauthorized activity on our platform. To achieve this, we will utilize a combination of internal controls and service agreements with software developers and other partners to ensure compliance.
A. Customer Due Diligence (KYC)
Remake.gg uses a risk-based approach to customer due diligence (CDD) in order to understand the purpose and nature of our user relationships and identify potential risks. This includes collecting relevant documentary and non-documentary information when users open accounts, based on the type of account and services being offered. Our customer due diligence (CDD practices are tailored to the specific accounts and services we offer.
Remake.gg's customer due diligence (CDD) process includes a customer identification program (CIP) that verifies the identity of our users and assesses any potential risks. The CIP includes procedures for gathering information about the user's business or financial activities. These procedures may vary depending on the user's relationship with Remake.gg and the level of risk involved. The CIP consists of procedures for:
- Obtaining basic information (such as wallet address and email address) through Remake.gg's user onboarding process at account creation;
- Evaluating the risk profile associated with the cryptocurrency wallet used to fund the user's account;
- Keeping records of the information used to identify the user;
- Checking if the user appears on any list of known or suspected terrorists or terrorist organizations based on the available information;
The following measures are used to implement the above steps:
- Identity and Age Verification: Remake.gg uses a third-party service provider to help verify the legitimacy of identification and KYC materials provided by users, as well as confirm that users are permitted to use our platform. The service provider also checks global sanctions lists to ensure that users are not located in a comprehensively-sanctioned or prohibited jurisdiction, using information such as wallet addresses provided during the onboarding process.
- Customer Information: To form a reasonable belief that we know the identity of our users, Remake.gg collects certain details, such as wallet address, name, address, country, date of birth, and postal code (collectively, "KYC Information"). This is done in accordance with the user's risk profile. Remake.gg requires this KYC Information before issuing a funding address to users. Currently, Remake.gg does not accept users who are non-natural persons. In some cases, Remake.gg may rely on another institution to fulfill some or all of the elements of our customer identification program (CIP).
- Geo-blocking for Prohibited Jurisdictions: Clients of Remake.gg must certify that they will not offer services in countries where such activity is prohibited by using IP address-based geo-blocking. This requirement is outlined in the contract.
- Geo-blocking for Sanctioned Jurisdictions: Remake.gg will require clients to certify that they and any associated individuals or entities are not subject to sanctions or watch lists in countries including the United States, European Union, Iran, Cuba, North Korea, Syria, and the Crimean region of Ukraine. These certifications will be verified through Know Your Customer (“ KYC ”) measures and IP address-based geo-blocking as part of the contract.
- Contractual Prohibitions on Users Onboarding from Prohibited Jurisdictions: Remake.gg informs users at the time of onboarding that it does not offer services in certain restricted jurisdictions including United States and Estonia. This policy is based on risk, fraud prevention, and AML standards, as well as assessments of the permissibility of its services in certain locations.
B. Enhanced Due Diligence and Ongoing Monitoring (KYC)
Remake.gg continuously monitors its users for behaviors or indicators that may be related to money laundering or terrorism financing. To identify such activities, Remake.gg has established a set of red flag indicators which prompt the company to further review customer information.
Whenever one of those red flags is triggered, the user account will be suspended and Remake.gg will pursue enhanced due diligence. Enhanced KYC diligence under this policy is deemed to include, but not limit to, the provision of: If a red flag indicator is triggered, Remake.gg will suspend the user account and conduct enhanced due diligence. This may include, but is not limited to, the provision of additional Know-Your-Customer (KYC) information, such as the following:
- Full legal name;
- Country of citizenship;
- A permanent address, which must be a residential or business street address for individuals and a principal place of business, local office, or other physical location for entities;
- An identification number, such as a taxpayer identification number, passport number and country of issuance, alien identification card number, or a government-issued document with a photograph or similar safeguard indicating nationality or residence;
- Government issued identification document;
- Information about the source of funds and wealth;
Remake.gg may utilize the services of a third party to verify any of the above information in order to determine the true identity of the user if the user's activity warrants it.
C. Acceptance Policy (KYC)
Remake.gg will definitely refuse access to users that:
- Do not provide the identification information requested by Remake.gg;
- Provide fake identification documents or invalid identification documents;
- Attempting to deceive about their location using various methods;
- Are from restricted or prohibited jurisdictions;
- Are included on sanctions or watch lists in the United States, European Union, or other countries;
- Suffer from gambling addiction or have mental health issues;
- Have sources of funds that originated or were exchanged in restricted jurisdictions;
Remake.gg reserves the right to block and suspend players for any other reasons at its own discretion.
Remake.gg is dedicated to adhering to economic and trade sanctions imposed by the locations in which it does business. To this end, Remake.gg has created a transaction monitoring program with controls and procedures to detect and identify any unusual activity in real-time and through ongoing monitoring.
Remake.gg will regularly conduct ongoing monitoring using both in-house and third-party systems to review user history and activity patterns. This is to detect and report any unusual activity, as well as to implement additional controls or limits on the platform as needed.
Remake.gg has established procedures to address the management of unusual or suspicious activity, including the following two key components:
- Identifying unusual activity, which may be done through employee and customer identification, law enforcement inquiries, referrals, or reports from transaction and surveillance monitoring systems; and
- Alert management, which involves processes for investigating, evaluating, and documenting identified unusual or potentially suspicious activity.
Remake.gg will use the following processes to achieve both goals:
- Transaction Monitoring for Sanctioned or Prohibited Jurisdictions: In its reasonable discretion, Remake.gg may request additional due diligence when a user requests a balance withdrawal. The company currently uses a combination of manual and automated transaction monitoring processes to identify red flag behavior. If such behavior is detected, Remake.gg may refuse to process the withdrawal or request additional information from the recipient. Remake.gg will also try to prevent users from funding their accounts using assets from prohibited jurisdictions, as identified in Remake.gg's user-facing disclosures and internally updated from time to time. For example, Remake.gg may prohibit a user from funding their account using a known Estonian or United States based exchange wallet, as this would indicate that the user is a United States or Estonian person. Users have the opportunity to provide additional information to rebut any suspension as part of Remake.gg's ongoing transaction monitoring and user due diligence standards.
- Screening for Sanctioned Parties: Before providing a Remake.gg Solana funding address (public key) to a user, the company will check the user's wallet address against relevant sanctions databases using third party blockchain forensics vendors like Chainalysis. Remake.gg will also periodically re-check wallet addresses against these databases.
- Identification of Unusual Activity: Remake.gg will monitor account activity for unusual transactions in terms of size, volume, pattern, or type, taking into account risk factors and red flags that are relevant to its business. This will involve regularly generating reports of unusual, high-risk, or suspicious user activity.
- Anti-Mixing Measures: Remake.gg will use software to detect suspicious deposit or withdrawal patterns. If such patterns are detected, the company will handle the situation on a case-by-case basis based on the perceived level of risk. In these instances, a user may be asked to explain their reasons for using the platform and their methodology.
- Chainalysis Review: All crypto deposits and withdrawals, both indirect and direct, will be processed through Chainalysis and reviewed for signs of fraud or suspicious behavior. If potential illicit behavior is detected, a user's account will be suspended and reviewed. High-risk accounts may be required to provide proof of wealth. Remake.gg may also refuse to withdraw to certain high-risk addresses as determined in consultation with Chainalysis's risk scoring.
- Withdrawal Threshold KYC: Every account, regardless of its association, will be suspended until sufficient KYC diligence is conducted once it reaches a withdrawal threshold based on the account's risk characterization over its lifetime.
D. Other Ongoing Monitoring Controls
In addition to the above-mentioned control procedures, Remake.gg has implemented the following procedures to supplement its KYC and ongoing monitoring processes:
- Ban Evasion Detection: In addition, Remake.gg will utilise third-party service provider software designed to detect banned users. This software relies on detection of links between the same devices used to access multiple accounts. Such instances will be handled on a case-by-case basis based on the perceived level of risk. In these situations, a user may be asked to explain their methodology and purpose for using the platform. Remake.gg accounts can be funded by users using local (non-custodial) or hosted (custodial) wallets. In addition to being screened by Chainalysis, Remake.gg monitors user activity within the platform and any withdrawals must pass Remake.gg's and its third-party service provider's automated verification processes. Remake.gg may also prohibit peer-to-peer account transfers within the platform at any time. Any attempts to bypass this restriction will be treated as a red flag.
- Time Zone Monitoring: Remake.gg has implemented time zone controls that use the user's device information and compare it to restricted jurisdictions to determine if the user is attempting to use geo location software to hide their location.
- Products and Services Review: Remake.gg will put additional procedures in place to prevent users from attempting to exploit the platform. The company has a set of user-facing terms that users must agree to in order to use the Remake.gg platform, and will implement additional safeguards to reduce the risk of misuse. For example, Remake.gg may establish policies or procedures for limiting which user assets can be used on the platform. The company lists the assets that are available for use on the platform and does not allow the use of anonymity enhancing technologies such as mixers, tumblers, or certain smart contracts that hide the identity of the source. If Remake.gg becomes aware that an anonymity enhancing technology is being used on the platform, it will suspend the user's account immediately.
- Vendor Management: Remake.gg partners with reputable third-party service providers as part of its compliance infrastructure. The company will periodically evaluate the performance and capabilities of these key providers to determine if additional services are needed, the provider is not fulfilling its contractual obligations, or if other corrective action is necessary for Remake.gg to comply with its policies. Remake.gg may request information from any third-party service provider as part of its vendor review process.
- Compliance Innovation: Aside from vendor management, Remake.gg will constantly monitor non-documentary compliance mechanisms to assess their suitability for the platform. Remake.gg may run test or trial programs with these compliance vendors on a limited basis to determine their effectiveness. Blockchain native compliance tools include fraud prevention services, on-chain KYC providers, and other tools designed to take advantage of the technological features of blockchain platforms.
6. Education and Training
Remake.gg may provide employees with AML, anti-terrorist financing, and trade sanctions compliance training on a regular basis, as deemed necessary, with the assistance of legal counsel and under the oversight of the CCO.
Remake.gg is required to report any unusual or suspicious transactions in accordance with the National Ordinance. Customers who are on sanctions lists, linked to money laundering or terrorism financing, or involved in other criminal activities will be reported as suspicious activity to the regulator.
© 2023 Copyright Remake.gg - Remake.gg is a registered trademark.
Remake.gg OÜ is registered under no. 16357307 in Estonia. Remake.gg is a competitive gaming platform for Counterstrike 2 and Dota 2. Remake.gg may not be available in countries that consider competitive gaming with winnings as gambling.
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