Anti-Money Laundering & Counter-Terrorist Financing (AML/CTF) Policy – DRAGON4DEALS

Effective Date: November 19, 2025

1. Introduction

This Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML/CTF Policy”) outlines the measures taken by DRAGON4DEALS LTD (“Dragon4Deals”, “we”, “our”, “us”) to prevent our platform from being used for money laundering, terrorist financing, or any other financial crime.

Dragon4Deals is committed to full compliance with all relevant AML/CTF laws and regulations in the United Kingdom and internationally. This policy is designed to protect our business, our customers, and the financial system from illegal activities.

This Policy is reviewed regularly (at least annually) and updated as needed to reflect changes in laws, risks, and our business operations.

2. Our Business and AML Risk

Dragon4Deals sells digital gift cards, gaming vouchers, wallet top-ups, and activation codes. Such digital goods can be vulnerable to misuse for fraud or financial crime if not properly monitored.
To mitigate these risks, we maintain strict verification, monitoring, and compliance procedures as set out below.

3. Definition of Money Laundering

Money laundering involves concealing or disguising the origin of funds obtained through illegal activities, making them appear legitimate.
Terrorist financing involves providing funds to support terrorism or extremist activities.

Examples of activities linked to financial crime include:

  • Use of stolen or fraudulent payment methods
  • Purchasing digital goods for rapid resale or laundering
  • Abuse of promotions or refunds
  • Transactions inconsistent with normal customer behaviour

Our policy prohibits and actively prevents all such activities.

4. Scope of This Policy

This AML/CTF Policy covers:

  • Customer Verification (KYC / CDD)
  • Payment Method Screening
  • Sanctions and PEP checks
  • Transaction Monitoring and Suspicious Activity Review
  • Record-keeping
  • Risk Assessment
  • Data Protection and Confidentiality
  • Responsibilities of the Compliance Officer

5. Customer Verification (KYC / CDD)

5.1 Identity Verification

Dragon4Deals may require customers to verify their identity when:

  • placing high-value orders,
  • using payment methods flagged for security review,
  • exhibiting unusual or high-risk behaviour,
  • accessing restricted functions.

Verification may include requesting valid documents such as:

  • Passport or national ID
  • Proof of address
  • Proof of payment method ownership

We reserve the right to refuse service if adequate verification cannot be completed.

5.2 Ongoing Monitoring

Customer identity information may be re-verified if:

  • data appears inconsistent,
  • suspicious activity is detected,
  • required by regulatory obligations.

All customer data is stored and protected in accordance with our Privacy Policy and applicable data protection laws.

6. Payment Method Controls

Customers using payment cards or digital payment methods may be subject to:

  • card ownership verification,
  • additional authentication steps,
  • security checks with payment processors.

Orders may be held, cancelled, or refunded if fraud is suspected.

7. Compliance Officer

Dragon4Deals appoints a dedicated Compliance Officer responsible for implementing and overseeing AML/CTF measures.
Responsibilities include:

  • Reviewing customer verification information
  • Maintaining AML/CTF policies and procedures
  • Monitoring transactions and investigating suspicious cases
  • Filing reports with relevant authorities when required
  • Ensuring proper record-keeping
  • Updating risk assessments

The Compliance Officer has full authority to act independently in compliance matters.

8. Sanctions, Adverse Media & PEP Screening

We screen customers and transactions against relevant lists, including:

  • International sanctions lists
  • UK sanctions lists
  • Politically Exposed Persons (PEP) lists
  • Adverse media databases

Screening occurs:

  • during onboarding for flagged accounts,
  • when transactions trigger alerts,
  • when required as part of enhanced due diligence.

Dragon4Deals does not transact with individuals or entities from jurisdictions subject to sanctions or high-risk restrictions.

9. Transaction Monitoring

We continuously monitor user activity to identify suspicious patterns.
Monitoring includes:

  • checking users against recognised watchlists,
  • detecting unusual order behaviour,
  • analysing payment inconsistencies,
  • aggregating transaction data for risk review.

9.1 Investigations & Case Management

Dragon4Deals may:

  • request additional user information,
  • temporarily hold or cancel orders,
  • suspend or terminate accounts,
  • report suspicious activity to relevant authorities.

These actions may occur without prior notice where necessary to comply with law or prevent financial crime.

10. Risk Assessment

We adopt a risk-based approach, assessing risks associated with:

  • customer profiles,
  • geographic locations,
  • payment methods,
  • unusual behaviour,
  • product usage.

10.1 Prohibited Jurisdictions

Dragon4Deals does not process transactions or provide services to customers associated with sanctioned or high-risk jurisdictions, including but not limited to:

  • Afghanistan
  • Central African Republic
  • Iraq
  • Lebanon
  • Somalia
  • Syria
  • Yemen
  • North Korea
  • Iran

We reserve the right to expand this list at our discretion.

11. Confidentiality and Data Protection

All customer data collected for AML/CTF purposes is confidential and handled according to applicable data protection laws.

Tipping off—informing a customer that they are under AML investigation—is strictly prohibited.

All employees receive AML/CTF awareness training appropriate to their role.

12. Zero-Tolerance Policy

Dragon4Deals enforces a strict zero-tolerance policy regarding money laundering, terrorist financing, fraud, and abuse.
Any violation may result in:

  • immediate account suspension,
  • cancellation of orders,
  • reporting to law-enforcement authorities,
  • permanent banning from our services.