1. Introduction

UPTHRONE INTERACTIVE LTD ("Repurpose Digital", "we", "us", "our") is committed to the highest standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. This policy outlines our procedures to prevent money laundering, terrorist financing, and other financial crimes.

Regulatory Framework: We comply with UK Money Laundering Regulations 2017, Proceeds of Crime Act 2002, and relevant EU directives including 5AMLD.

2. Risk Assessment

Customer Risk Categories

Low Risk: Individual creators, small businesses with verified payment methods
Medium Risk: New businesses, high-volume credit purchases, international transactions
High Risk: PEPs, sanctioned countries, unusual transaction patterns

3. Customer Due Diligence (CDD)

Standard CDD Measures

Identity verification through government-issued ID
Address verification via utility bills or bank statements
Business verification for corporate accounts
Source of funds verification for large purchases (>€1,000)
Ongoing monitoring of account activity

Enhanced Due Diligence (EDD)

Applied for high-risk customers and transactions over €5,000:

Additional identity documentation
Senior management approval
Enhanced transaction monitoring
Regular review cycles (quarterly)

4. Transaction Monitoring

Suspicious Activity Indicators

Multiple credit purchases from different cards within 24 hours
Purchases significantly exceeding typical usage patterns
Requests for refunds to different payment methods
Use of anonymizing services or suspicious IP addresses

5. Credit System & Financial Controls

Credit Purchase Limits

Daily limit: €5,000 per account
Monthly limit: €20,000 per account
Single transaction limit: €2,500
Automatic review for purchases over €1,000

Credit Usage Tracking

All credit transactions are monitored and recorded:

1 credit = €0.08 fixed value
Complete audit trail of credit purchases and usage
Real-time fraud detection system
Monthly reconciliation reports

6. Reporting Obligations

Suspicious Activity Reporting

We report suspicious activities to:

UK National Crime Agency (NCA)
Financial Conduct Authority (FCA)
HM Revenue & Customs (HMRC)
Payment processor (Ecommpay) compliance team

Timeline: Within 24 hours of detection or as required by law

7. Record Keeping

We maintain comprehensive records in accordance with legal requirements:

Customer identification records: 5 years after relationship ends
Transaction records: 7 years for tax purposes
Suspicious activity reports: 5 years
Risk assessments: Updated annually

8. Training & Awareness

All staff receive mandatory AML/KYC training:

Initial training upon onboarding
Annual refresher courses
Updates on regulatory changes
Role-specific training for compliance team

9. Contact Information

For AML/KYC inquiries or to report suspicious activity:

Compliance Officer: David Thompson

Email: compliance@repurpose.digital

Phone: +44 (20) 555-0199

Address: 60 Tottenham Court Road, Office 314, Fitzrovia, London, W1T 2EW, UK

This policy was last updated on January 20, 2025 and is reviewed annually.

AML & KYC Policy