Login
Register
Login
Register

Privacy policy

P2GIVE EOOD

ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY

(AML/CTF Policy of the Play to Give Platform)

Preamble

This Policy governs the measures applied by P2GIVE LTD (the “Company”) to prevent money laundering and terrorist financing (“ML/TF”) in connection with the activities of the Play to Give platform and forms an integral part of the Platform’s General Terms and Conditions. The Company is not a payment service provider and does not hold Client funds. Nevertheless, given the multi-level structure of the Platform’s affiliate network and the existence of a product category with a higher inherent risk (entertainment services/gambling), the Company applies this Policy voluntarily and preventively, in accordance with the Bulgarian Measures Against Money Laundering Act (“MAMLA”), the Measures Against the Financing of Terrorism Act (“MAFTA”), and Directive (EU) 2015/849, as amended by Directive (EU) 2018/843 (“Fifth Anti-Money Laundering Directive”). Each licensed Product Partner in the “Entertainment Services/Gambling” category additionally applies its own independent AML program in accordance with the requirements of its license. This Policy governs P2GIVE’s measures relating to the affiliate network, commission flows and the donation mechanism and does not replace the obligations of the respective licensed operator.

Section I. General Provisions

Art. 1. The purpose of this Policy is to prevent the Platform, including the affiliate network, commission flows and the Donation Fund, from being used for money laundering, terrorist financing or other unlawful financial activities. Art. 2. The Policy applies to all Participants — Affiliates, Clients and Sports Clubs — as well as to all Product Partners, to the extent applicable according to their respective regulatory status. Art. 3. This Policy shall be interpreted together with the “AML and KYC Policy” section of the Platform’s General Terms and Conditions and Annex A thereto.

Section II. Definitions

§1. “Money Laundering (ML)” means the activity of concealing the origin of funds obtained through criminal activity by introducing them into the legitimate economy. §2. “Terrorist Financing (TF)” means the provision or collection of funds with the intention or knowledge that they will be used for terrorist activities. §3. “Ultimate Beneficial Owner (UBO)” means the natural person who ultimately owns or controls a Participant that is a legal entity, in accordance with MAMLA. §4. “Politically Exposed Person (PEP)” means a person who holds or has held a prominent public function, in accordance with the legal definition under MAMLA. §5. “Customer Due Diligence (CDD)” means the standard measures for identifying and verifying the identity of a Participant. §6. “Enhanced Due Diligence (EDD)” means additional verification measures applied to Participants or transactions presenting a higher level of risk. §7. “Suspicious Transaction” means a transaction, commission pattern or donation in relation to which there are grounds to suspect a connection with ML/TF or another unlawful activity. §8. “AML Compliance Officer” means the person designated by the Company to implement this Policy and maintain contact with the competent authorities.

Section III. Risk-Based Approach and Specific Risks of the Multi-Level Structure

Art. 4. The Company applies a risk-based approach that takes into account, in particular, the risks inherent in a multi-level affiliate structure (MLM) combined with different product categories. Art. 5. The main risk scenarios specific to the multi-level structure include:
  1. “layering” through the distribution of commissions among multiple related or fictitious profiles at different levels of the Network;
  2. “structuring” or the artificial splitting of amounts among several Downline profiles in order to avoid verification thresholds;
  3. registration of fictitious or non-existent Participants solely for the purpose of generating or redirecting commissions;
  4. repeated purchases and returns of the same Product in order to artificially generate a Commission Fund without actual consumption; and
  5. use of the Donation Fund to give an appearance of legitimacy to funds of unclear origin.
Art. 6. The “Entertainment Services/Gambling” category represents an additional risk factor due to the higher inherent ML/TF risk in the gambling sector in general, even though the respective activity is carried out by an independent licensed third party and not by the Company. Art. 7. The high value of an individual Purchase (for example, in the “Motorcycles and Accessories” category) constitutes another risk indicator requiring enhanced attention, as such Purchases may be used to introduce a large amount of money into the system through a single transaction. Art. 8. The Company periodically, and at least once a year, reassesses the Platform’s risk profile and updates this Policy accordingly.

Section IV. Participant Due Diligence (CDD/KYC)

Art. 9. Upon registration, every Affiliate and every Client who makes a Purchase in the “Entertainment Services/Gambling” category or a Purchase above a specified monetary threshold shall undergo a due diligence procedure including an identity document, address and, in the case of legal entities, information about the ultimate beneficial owner. Art. 10. Due diligence is mandatory before the first payment of commissions to an Affiliate, regardless of the amount. Art. 11. Enhanced due diligence applies to:
  1. Participants identified as politically exposed persons;
  2. Participants residing in jurisdictions with a high ML/TF risk according to the lists of the European Commission and FATF;
  3. Affiliates whose Network grows at an unusually high rate without corresponding real product activity; and
  4. Participants associated with a Suspicious Transaction within the meaning of this Policy.
Art. 12. The Company screens Participant data against the current sanctions lists of the European Union, the United Nations and, where applicable, the United States Office of Foreign Assets Control (OFAC), upon registration and periodically thereafter. Art. 13. A Participant’s refusal to provide the documents or information required under this section constitutes grounds for refusal of registration, suspension of payments or termination of participation in accordance with the Platform’s General Terms and Conditions.

Section V. Monitoring of Commission Flows and Transactions

Art. 14. The Company performs automated monitoring and periodic manual reviews of commission flows within the Network in order to identify patterns corresponding to the risk scenarios described in the section on the risk-based approach.
Indicator Threshold / Pattern Action
Accumulated Affiliate commission for a Reference Period above €2,000 or a sharp increase (>300%) compared to the previous period Review by the AML Compliance Officer before payment
Individual Purchase above €1,500 (e.g. “Motorcycles” category) Verification of the source of funds before confirming the Purchase
Repeated purchases/returns of the same Product by a Client 3 or more cycles within 30 days Temporary suspension of the related commissions until the circumstances are clarified
Newly registered Affiliates within the same Downline more than 10 new profiles within 7 days without corresponding product activity Enhanced due diligence of the entire affected line
Individual donation to a Sports Club above €1,000 and outside the club’s usual volume Verification and confirmation of the source of funds before distribution
Art. 15. The review referred to in the preceding article does not automatically suspend payment unless the AML Compliance Officer determines that there is reasonable suspicion; in such a case, the withholding period provided for in the verification section of the General Terms and Conditions shall apply (up to 180 days).

Section VI. “Know Your Affiliate” (KYP): Specific Measures for the MLM Network

Art. 16. In addition to standard identity due diligence, the Company periodically verifies whether an Affiliate’s commissions originate from real product activity within their Network rather than solely from internal transfers or self-referrals. Art. 17. An Affiliate whose Network generates commissions primarily through the registration of new participants without comparable real consumption of Products shall be subject to enhanced due diligence and may be requested to provide additional explanations and documents.

Section VII. Reporting of Suspicious Transactions

Art. 18. Any employee or authorized representative of the Company who identifies a transaction related to ML/TF, or has reasonable grounds to suspect such a connection, must immediately notify the AML Compliance Officer. Art. 19. The AML Compliance Officer shall assess the report and, where applicable under the legislation in force, shall submit it to the competent national authority (in the Republic of Bulgaria — the Financial Intelligence Directorate of the State Agency for National Security). Art. 20. It is prohibited to inform the affected Participant about a submitted suspicious transaction report (prohibition of “tipping-off”). Art. 21. The Company and its employees shall not be liable for reports submitted in good faith under this section, even if the suspicion is subsequently not confirmed.

Section VIII. Record Keeping

Art. 22. Documents and data collected under this Policy shall be retained for at least 5 (five) years after termination of the relationship with the relevant Participant, unless applicable law requires a longer period. Art. 23. Documentation shall be stored in a manner that ensures confidentiality and protection in accordance with the Company’s Privacy Policy.

Section IX. Responsibility, Training and Internal Control

Art. 24. The Company shall designate an AML Compliance Officer responsible for implementing, updating and monitoring compliance with this Policy. Art. 25. Employees and authorized representatives of the Company involved in processing registrations, payments or verifications shall undergo periodic training to recognize the risk scenarios described in this Policy. Art. 26. The AML Compliance Officer shall prepare an annual internal report on the implementation of the Policy and the identified risk trends.

Section X. Consequences of Non-Compliance

Art. 27. A Participant’s failure to comply with this Policy constitutes grounds for applying the measures provided for in the sections of the Platform’s General Terms and Conditions relating to reviews, suspension of payments, investigations and/or termination of participation. Art. 28. The Company reserves the right to reject or cancel a Purchase, commission or donation where the lawful origin of the funds cannot be established.

Section XI. Final Provisions

Art. 29. This Policy shall be updated periodically, including where there is a change in the applicable legislation or in the Platform’s risk profile. Art. 30. This Policy forms an integral part of the General Terms and Conditions of the Play to Give platform.