1. Our Commitment
SKINS24 takes a zero-tolerance stance on money laundering, terrorist financing, and other financial crime. This Anti-Money Laundering (AML) Policy describes how we meet our obligations under the EU Anti-Money Laundering Directives — including the Sixth AML Directive — and any other AML rules that apply where we operate.
Every employee, contractor, and partner involved in SKINS24 operations must follow this policy.
2. Risk Assessment
We run regular risk assessments to spot and evaluate the money-laundering and terrorist-financing risks relevant to our business. The assessments consider what we sell (digital goods), where our customers are based, the transaction profiles we see, and the payment methods we support.
The findings steer our due-diligence procedures, monitoring thresholds, and internal controls.
3. Customer Due Diligence
Standard: every user is identified through Steam OAuth, which ties the account to a verified Steam profile. The payment processor adds a second layer of verification via cardholder checks and 3D Secure.
Enhanced: users whose activity exceeds risk thresholds or who fall into higher-risk categories may be asked for additional documentation — a government-issued photo ID, proof of address, source-of-funds evidence — and face closer ongoing monitoring.
Simplified: applied where the risk assessment clearly supports a lower-risk rating, in line with the relevant regulations.
4. Transaction Monitoring
All transactions are monitored through a blend of automated rules and human review. Triggers that warrant further attention include: unusually large or frequent purchases that don't fit the user's profile; rapid buy-and-sell patterns suggestive of layering; activity linked to sanctioned jurisdictions; multiple payment instruments tied to a single user; and any activity that diverges meaningfully from typical marketplace behaviour.
Alerted transactions are reviewed promptly. Next steps may include requesting further documentation, placing the transaction on hold, or filing a suspicious activity report.
5. Sanctions Screening
We screen users and transactions against the sanctions lists published by the European Union, the United Nations, and the U.S. Office of Foreign Assets Control (OFAC). A positive match results in an immediate account suspension and a block on any further activity.
6. Reporting Obligations
Where we identify suspicious activity, we file a Suspicious Activity Report (SAR) — or equivalent Suspicious Transaction Report (STR) — with the competent Financial Intelligence Unit as required by law. We cannot legally alert the user that a report has been or might be filed (“tipping off”).
SKINS24 reserves the right to freeze accounts, withhold funds, and suspend pending deliveries while investigating potentially unlawful activity.
7. Record Keeping
Customer identification records, transaction logs, and internal reports are retained for at least 5 years after the end of the business relationship or the transaction date — whichever is later. Records are stored securely and made available to competent authorities in response to lawful requests.
8. Staff Training
Every relevant team member completes AML training at onboarding and at regular intervals thereafter. The programme covers the legal framework, our own procedures, how to recognise suspicious activity, and reporting duties. Attendance is logged and retained.
9. Policy Review
This AML policy is reviewed at least annually, and more often if our business, the regulatory environment, or our risk profile changes materially. Any revisions are signed off by senior management and rolled out to the team.
Contact
Questions about this policy? Write to legal@skins24.co.uk.