SPIN SORCERY CUSTOMER ACCEPTANCE POLICY

 

VERSION: 1.0

DATE OF LAST UPDATE: May 24th, 2024

 

1.    WHO WILL SPIN SORCERY ACCEPT AS A CUSTOMER?

Spin Sorcery will do business with you, only if you:

1.1. are a natural person (Spin Sorcery does not accept companies or any other legal entities as customers).

1.2. have read and agreed to the most recent applicable Terms and Conditions (including any applicable Privacy Policy, Sweeps Rules, Responsible Social Gameplay and this Customer Acceptance Policy).

1.3. follow such Terms and Conditions at all times.

1.4. register with and transact on any Spin Sorcery platform on your own behalf.

1.5. use payment mediums for which you are the legal and beneficial owner.

1.6. are over the age of 18 years.

1.7. reside in the United States (excluding the State of Idaho, Michigan, Nevada and Washington)

1.8. are satisfactorily identified and verified under Spin Sorcery's Anti-Money Laundering policy.

1.9. satisfy Spin Sorcery's due diligence measures (as applicable) including source of wealth and funds checks.

1.10. provide information and documents as requested by Spin Sorcery, in accordance with Spin Sorcery's Anti-Money Laundering policy.

1.11. are not:

a. a politically exposed person (past or present) (PEP).

b. a family member or close associate of a PEP.

c. you are named on any sanctions list issued by the OFAC.

d. directly or indirectly linked to countries or territories subject to comprehensive sanctions.

e. an individual with a risk profile falling outside of Spin Sorcery's risk tolerance as determined in Spin Sorcery's sole discretion.

If you are accepted as a customer, Spin Sorcery may ask you to give extra information if Spin Sorcery either:

1.12. classifies you as high risk.

1.13. or deems the extra information necessary from time to time.

 

2.    WHAT MAKES SPIN SORCERY CLASSIFY A CUSTOMER AS HIGH RISK?

Spin Sorcery continually screens accepted customer's information, purchases, redemptions, game activity and behaviors for relevant financial crime risk indicators. Depending on the specific facts and context, customers will be classified as having a low, medium or high-risk level. Spin Sorcery will classify a customer as high risk where they present or are likely to present money laundering, funding of terrorism or other financial crime risk which has financial or reputational consequences to Spin Sorcery.

While Spin Sorcery seeks to investigate any financial crime risk alerts within a reasonable timeframe, compliance with applicable laws may result in delays while additional due diligence is conducted and relevant information obtained.

 

3.    WHAT KIND OF EXTRA INFORMATION WILL SPIN SORCERY REQUEST?

If Spin Sorcery classifies you as high risk or determines that extra information is required, you may be asked to provide information on, or evidence of, your:

3.1. income-generating activities.

3.2. estimated net worth or sources of wealth.

3.3. anticipated pattern and level of Gold Coins purchases.

3.4. sources of funds used on a particular Gold Coins purchase transaction or series of Gold Coins purchase transactions.

3.5. identity attributes in question including name, date of birth and address.

If you fail or refuse to submit, within the timeframe communicated by Spin Sorcery, the required information, Spin Sorcery reserves the right to terminate the business relationship with you and close your account.

 

4.    WHY DOES SPIN SORCERY DO THIS?

Spin Sorcery is required to maintain an Anti-Money Laundering policy which includes assessing the level of financial crime risk presented by its customers and accepting only those customers whom it assesses as having an acceptable level of risk. This requirement is set by:

4.1. the laws applicable to Spin Sorcery.

4.2. its third-party service providers.

 

5.    WHAT ARE THE KEY ASPECTS OF SPIN SORCERY'S ANTI-MONEY LAUNDERING POLICY?

The key aspects of Spin Sorcery's Anti-Money Laundering policy include but are not limited to:

5.1. the appointment of a money laundering reporting officer or alternative position as required by local regulation.

5.2. a customer due diligence program incorporating customer identification and verification based on information issued or obtained from independent and reliable sources and know your customer principles.

5.3. conducting enhanced due diligence on customers assessed as higher risk.

5.4. implementing processes and systems to monitor customer transactions to identify suspicious activity.

5.5. investigating and, where appropriate, reporting suspicious activity to applicable regulatory bodies.

5.6. compulsory training of Spin Sorcery employees and contractors in relation to financial crime risks.

5.7. prohibiting business with customers with an unacceptable level of risk.

5.8. continually monitoring levels of purchases and redemptions and evaluating these against anticipated account activity, the estimated net worth of the customer and the data and information retained on the customer's economic profile.

5.9. investigating any significant deviations in what Spin Sorcery understands of a customer's economic profile and their level of purchases.

5.10. additional local requirements applicable to Spin Sorcery from time to time.