📕AML-policy of Sportoner (EN)
Sportoner Labs Corp., a company incorporated under the laws of the Republic of Panama, with registration number 155771837, registered office at 55th street East, P.H. SL55 Building, Floor 21, Suite 3, Panama City, Republic of Panama (“Sportoner”, “we”, “us”, “our”), and you, the individual registering and accessing our web services (“User”, “you”), agree to this Anti-Money Laundering Policy (“Policy”), which governs your access to and use of https://app.sportoner.com (the “Website”) and all applications owned and operated by Sportoner (the “Apps”).
1. General Provisions
1.1. The terms used in this Policy shall have the same meaning as defined in the Terms of Use, unless otherwise stated.
1.2. Please read this Policy carefully before using the Website and platform (the “Services”).
1.3. You are required to read and understand this Policy before accessing the Services, as it is one of the documents ensuring proper and secure use of the Services. This Policy sets out the requirements for the identification, verification, and ongoing monitoring of our Users and their transactions in order to prevent, detect, and report criminal activities, money laundering, terrorism financing, sanctions violations, and tax evasion.
1.4. The provisions of this Policy apply to all actions governed by the Terms of Use available on the Website.
2. Definitions
For the purposes of this Policy, the following terms are defined as follows:
2.1. Money Laundering (ML) – any activity involving property derived from criminal activity or property substituted for such property, intended to conceal or disguise the true nature, origin, location, disposition, movement, ownership, or rights associated with such property; or converting, transferring, acquiring, possessing, or using such property to hide its illicit origin or to assist any person involved in criminal conduct to evade the legal consequences of such conduct.
2.2. Terrorism Financing (TF) – the provision or collection of funds, by any means, directly or indirectly, with the intention or knowledge that such funds will be used to carry out a terrorist act, support its commission, or fund travel for terrorist purposes as defined under applicable laws.
2.3. International Sanctions – non-military measures imposed by the United Nations or other international organizations aimed at maintaining or restoring peace, preventing conflicts, reinforcing international security, promoting democracy, rule of law, human rights, and compliance with international law.
2.4. AML Compliance Officer – the individual appointed by the President of Sportoner, responsible for overseeing the effectiveness and implementation of this Policy.
2.5. Business Relationship – any relationship established between Sportoner and a User in the course of our economic and professional activities.
2.6. User – a natural person using the Services.
2.7. Transaction – a transfer of virtual assets initiated by the User from their wallet to a custodial wallet managed by Sportoner via Sportoner’s platform.
2.8. Beneficial Owner – a natural person who ultimately owns or controls a transaction, operation, or another person, or on whose behalf such transaction or operation is carried out.
2.9. Politically Exposed Person (PEP) – a natural person who is or has been entrusted with prominent public functions, or a close family member or associate of such person, including senior officials of international organizations.
2.10. Virtual Currency – a digital representation of value that can be digitally transferred, stored, or traded and is accepted by persons as a means of payment but is not considered legal tender in any jurisdiction.
3. AML Compliance Officer
3.1. Sportoner appoints an AML Compliance Officer whose core responsibilities include:
ensuring compliance of this Policy with applicable laws and regulations;
collecting and regularly updating information regarding low-tax-risk jurisdictions, high ML/TF risk countries, and economic activities vulnerable to ML/TF;
training and informing staff members;
reporting on compliance with this Policy to Sportoner management;
collecting, processing, and analyzing information received from employees or Users regarding suspicious or unusual activities;
receiving internal reports and submitting proposals to address deficiencies identified during inspections.
4. Due Diligence Measures
4.1. The Service shall determine and apply due diligence (“DD”) measures based on risk assessment outcomes.
4.2. DD measures include:
identifying the User and verifying their identity using reliable and independent sources, documents, or data, including electronic identification;
identifying and verifying the representative of the User and their authorization;
identifying the User's beneficial owner;
assessing and obtaining information regarding the purpose of the business relationship;
determining whether the User is a PEP, a family member, or a close associate of a PEP;
identifying whether any international sanctions apply to the User, their beneficial owner, representative, director, or any associated persons.
4.3. In order to fulfill due diligence obligations, Sportoner is entitled to:
request documents and information related to the User’s activities and the lawful origin of funds;
request identification documents of the User and their representatives;
request information about the User’s beneficial owners;
assess the User's risk profile, apply appropriate DD measures, and evaluate the risk of the User’s involvement in ML/TF;
re-identify the User or their representative if there are doubts about the accuracy of previously obtained information;
decline to carry out or participate in a Transaction if there is suspicion of ML/TF involvement or that the User or a related party is engaged in or may be engaged in ML/TF.
4.4. The goal of continuous DD measures is to ensure ongoing monitoring of Users and their Transactions.
4.5. Sportoner shall update User information and apply appropriate DD measures in the following cases:
after initial identification and verification;
based on update conditions which vary by User risk classification;
upon receiving information from third parties or the media indicating material changes in the User’s activities or data;
if transaction data reflects significant changes in the User’s business scope or volume, requiring reassessment of the User's risk profile.
5. Identification of Individuals
5.1. The following persons are subject to identification under DD procedures:
The User (natural person);
The User’s representative (natural person authorized to act on the User's behalf);
The User’s beneficial owner;
any PEP, where applicable.
5.2. When establishing a business relationship, Sportoner identifies and verifies the User via information technology tools and adheres to technical standards for remote identification via electronic video transmission devices.
5.3. Consequences of insufficient identification:
immediately apply enhanced DD measures;
reassess and escalate the User’s risk profile. Notify the AML Officer, and in high-risk cases, escalate to the Company President;
review all previous transactions of the User to identify any previously undetected suspicious activity.
6. Determining the Purpose and Nature of Transactions
6.1. To detect suspicious or unusual transactions and establish the purpose and actual nature of a transaction, Sportoner may:
request additional information about the User’s professional or economic activity for Transactions exceeding certain thresholds;
request explanations and, where necessary, supporting documents regarding the source of funds and/or wealth;
pay particular attention to Transactions involving individuals or entities from jurisdictions where obtaining reliable information is especially difficult or jurisdictions with limited AML frameworks.
7. Risk Assessment
7.1. Sportoner conducts risk assessments of its operations and Users, establishes the User’s risk profile based on registration data, and applies appropriate levels of due diligence accordingly.
8. Prohibited Transactions
8.1. The User agrees to use the Service strictly in accordance with the Terms of Use, including this Policy, and solely for personal purposes. The User shall not sell, rent, or otherwise grant third-party access to the Services.
8.2. The following actions and Transactions are prohibited:
The User lacks sufficient authorization to conduct the Transaction, or such authority is unclear;
the necessity of the Transaction is not justified by reasonable grounds;
The User is a fictitious person;
The User or their representative refuses to provide information necessary to establish the nature of the Transaction and assess the risk;
The User fails to provide adequate documentation evidencing the lawful origin of assets when requested;
credible sources (e.g., governmental agencies, international organizations, media) report the User, their beneficial owner, or associated persons have been or are involved in organized crime, ML, TF, tax evasion, bribery, or corruption;
The User or their associates are linked to criminal sources of income, such as illicit trade in excise goods, drugs, arms trafficking, human trafficking, prostitution, or unlicensed digital asset transfers;
The User, their representative, or beneficial owner is subject to international sanctions;
The User promotes, encourages, or facilitates violence or any illegal activity.
9. Data Retention
For details on how we collect, use, and share User information, please refer to our Privacy Policies:
10. Reporting Suspicious Transactions
10.1. Any unusual or suspicious circumstances identified within the business relationship that may indicate ML, TF, or attempted such activities must be immediately reported to the AML Officer.
10.2. The AML Officer shall analyze and escalate the relevant information to the President of the Company.
11. Application of International Sanctions
11.1. Sportoner conducts screening and applies special attention to all Users (existing and new) concerning activities, facts, and indicators suggesting that a User may be subject to applicable international sanctions.
12. Restricted Jurisdictions
12.1. The following jurisdictions are restricted: Albania, Afghanistan, Bahamas, Barbados, Botswana, Burkina Faso, Cambodia, Cayman Islands, Cuba, Democratic People’s Republic of Korea (North Korea), Haiti, Ghana, Jamaica, Iran, Iraq, Gibraltar, Mauritius, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Trinidad and Tobago, Uganda, Vanuatu, Yemen, Angola, Burundi, Central African Republic, Republic of the Congo, Democratic Republic of the Congo, Guinea-Bissau, Liberia, Libya, Mali, Sierra Leone, Somalia, Côte d'Ivoire, United States of America (USA), Zimbabwe, Puerto Rico, U.S. Virgin Islands, any other U.S. territories or countries where digital asset operations are prohibited or otherwise restricted.
12.2. U.S. User Restrictions: You represent and warrant that you are not a U.S. citizen, do not hold permanent residency or Green Card status in the U.S., are not a U.S. tax resident under U.S. law, and have not been present in the U.S. for a period sufficient to be considered a tax resident. Furthermore, your entity is not incorporated in the United States.
12.3. Otherwise, the User must immediately cease use of the Website and Services.
12.4. Service Sale Restrictions: Sportoner does not provide Services to Users in jurisdictions where interaction with cryptocurrencies is prohibited by local law.
12.5. Countries Where Crypto Is Prohibited for Individuals: Iraq, China, Algeria, Bangladesh, Egypt, Afghanistan.
12.6. Sportoner reserves the right to determine the jurisdictions and markets in which it operates and may restrict or deny Services in any country or region as necessary based on its risk appetite or applicable law, authority requirements, or sanctions programs. You must promptly notify us if you become a resident of any restricted jurisdiction. You understand and acknowledge that providing false information about your location or residency may result in the termination of your access to the Services and legal action under applicable law.
13. Contact Information
If you have any questions regarding this Policy, please do not hesitate to contact us:
[email protected] 55th Street East, P.H. SL55 Building, Floor 21, Suite 3, Panama City, Republic of Panama
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