In accordance with this Midas Games – Anti-Money Laundering and Counter-Terrorism Financing Policy (“Policy”), MIDAS GAMES KFT (“Company”); Registration number: 01-09-432808 Registered Seat: 1064 Budapest, Izabella utca 68/B A. lház. Fsz. 5. Ajtó Hungarian VAT Number: 32600207-2-42 EU VAT Number: HU32600207, agrees and undertakes to act with the purpose of preventing primarily money laundering and terrorism financing, as well as other crimes. In this context, the Policy has been drafted to ensure the Company’s compliance with relevant national and international regulations and to guarantee adherence to legal, ethical, and professional standards in its business operations. We find it important to state that the Company is very sensitive about preventing money laundering and financing of terrorism issues. In fact, all necessary internal procedures are prepared in this regard, potential risks are meticulously identified and reported, all kinds of measures are taken to reduce these risks as a result of the relevant reports, and actions are taken regarding audits. The Company has adopted a zero-tolerance principle regarding money laundering and terrorism financing.
The Company is committed to full compliance with national and international regulations related to money laundering and terrorism financing. Primarily, the Company diligently follows Anti-Money Laundering (“AML”) laws and Know Your Customer (“KYC”) regulations, as well as the guidelines issued by the Financial Action Task Force (“FATF”), International Monetary Fund (“IMF”), and other relevant organizations. The full compliance process involves observing all relevant legal documents, including national and international laws, regulations and directives, and prioritizing all steps that need to be taken by the Company to comply with them. Subsequently, the Company reviews and updates the Policy accordingly. In order to support the Company's full compliance, the publications and broadcasts of the relevant institutions are regularly monitored, the relevant departments are assigned to this matter, and in case of questions or gaps, the institutions that issue them are directly contacted and clarified.
The Company’s board of directors is responsible for determining the policies and strategies in the fight against money laundering and terrorism financing, as well as for implementing, monitoring, developing, and reporting these strategies in daily operations. The board of directors is responsible for carrying out this policy, strategy determination and reporting work in light of current national and international financial and legal developments. In this case, the board of directors follows all legal and financial developments related to the subject and updates the policies and procedures accordingly. The board of directors attaches great importance to the updating of these policies and procedures in order to ensure the accuracy of the necessary strategic methods and also aims to minimize possible risks by reporting them regularly. Additionally, the board of directors allocates the necessary resources and ensures the formation of the required units to ensure the effective implementation of the Policy. The Board of Directors is responsible for organizing various trainings in order to increase the awareness of employees in the relevant units on money laundering and financing of terrorism. Within the scope of these trainings, the relevant personnel are informed about acting in accordance with the principle of transparency and accountability both in monitoring and reporting transaction reports and in general in the implementation of policies and procedures.
The Company regularly conducts risk assessments to identify and effectively manage the risks of money laundering and terrorism financing. By applying strategies to accept, mitigate, transfer, or avoid risks, the Company aims to identify risk factors, prioritize risks, and ensure appropriate controls. The Company considers various factors, such as the profile of customers and business partners, transaction volume, and geographical location, to timely identify risks and take appropriate measures. The Company prepares plans and procedures for possible high-risk scenarios, determines the steps to be taken in the event of the relevant scenarios, and makes preliminary preparations for their implementation. In this case, attention and care are encouraged within the Company and efforts are made to prevent problems that may arise from possible risks.
The Company acts diligently in the customer acceptance process and implements identity verification procedures before establishing any transactions. These procedures include the collection, verification, and monitoring of customer identity information. The company utilizes the latest technological developments by using all kinds of artificial intelligence-supported verification tools, including biometric verification, to ensure the most accurate identification during the verification process and to prevent potential imposters. To verify the identity information of customers, the Company may initiate contact with the customer who issued the document to confirm the accuracy of the information. The company ensures that all identity verification procedures are carried out in full compliance with both national and international privacy and data protection laws, so clients can feel confident that their data is secure throughout the entire process. In this context, no transactions are allowed for a customer until their identity information is verified. To identify high-risk customers, the Company considers various risk factors, such as the customer's transaction volume and geographical location. To evaluate possible risks more thoroughly, other elements like the customer's business type, funding source, and participation in high-risk industries are also taken into consideration. The Company has developed and operates an effective system to monitor suspicious activities in customer accounts, with the capability to identify, assess, and report unusual or suspicious activities. The purpose of using the relevant system is to provide rapid detection of potential money laundering and other suspicious activities. At the same time, the system increases the probability of correctly identifying potential risks. In fact, the system analyzes based on time and provides accurate detection of suspicious activities with various algorithms. The Company regularly reviews and updates its customer acceptance policy and procedures in line with changing legal regulations, international standards, and its operations. The relevant policies and procedures are updated by the unit assigned to this matter in accordance with the results obtained by following national and international standards. In this sense, the company ensures that the customer acceptance phase, which it considers very important in terms of preventing money laundering and terrorist financing, is in compliance with current laws and standards. Information and documents related to customers are kept by the Company and are presented to relevant public authorities upon request. The Company also ensures that these records are securely stored using industry-leading data protection measures, safeguarding sensitive information while maintaining compliance with privacy laws.
The Company provides regular training to all its employees on combating money laundering and terrorism financing. The training programs, exclusively determined by the Company, include the relevant legislation and the Company's Policy on detecting, preventing, and reporting money laundering and terrorism financing. Within the scope of the relevant programs; there are many different activities, including scenarios regarding possible risks, in order to raise awareness among employees. In this sense, the type of training is diversified so that employees can turn their theoretical knowledge into practice. In this regard, all employees receive the necessary training to comply with the Policy and report suspicious activities, actively playing a role in identifying and mitigating the risks of money laundering and terrorism financing. In this sense, as a result of in-company training; employees increase their awareness of suspicious activities and their possible consequences. Employees are encouraged to be much more careful in detecting, reducing and recognizing possible dangers and risks related to money laundering and terrorist financing. Additionally, the Company aims to increase awareness on these issues by developing informative materials and organizing seminars at its discretion, beyond the scope of the training programs. The Company's aim in this regard is to ensure that personnel actions are in compliance with relevant policies, procedures and strategies, and to raise the knowledge of relevant personnel on money laundering and terrorist financing issues above the sectoral level.
To effectively combat money laundering and terrorism financing, the Company continuously strengthens and develops its internal control and audit mechanisms. These mechanisms aim to detect and evaluate suspicious activities and promptly report them to the relevant authorities. This is a requirement of compliance with the principles of accountability and transparency, which the Company attaches great importance to. Additionally, the Company consents to inspections related to this matter. In this case, transparent access to records and processes will be provided to the relevant audit mechanism. By fostering a collaborative relationship with oversight bodies and staying responsive to their feedback, the Company ensures its practices remain aligned with the highest standards of integrity. The company attaches great importance to the feedback it receives as a result of relevant audits and immediately begins to implement them by incorporating them into company policies and other relevant documents. In this way, the company aims to comply with the standards of the relevant regulatory bodies.
The Company acts diligently in its relations with business partners regarding the fight against money laundering and terrorism financing. Adopting a zero-tolerance principle in this matter, the Company assesses whether business partners share the same sensitivity, their suitability, and reliability, and ultimately the purpose and nature of the business relationship. This evaluation is made by taking into account both the partners' attitudes on the subject and the policies and previous actions. In this sense, the aim is to increase the sensitivity of the partners on this subject by considering the reputation of the company and to keep the relevant subject ahead of financial expectations and goals in any case. The Company does not establish any business relationship without verifying the stated information. In fact, the company prioritizes accountability and trust in its commercial relations and establishes alliances that are compatible with this. We would like to emphasize again that the company's financial expectations and objectives never intersect with money laundering and providing financial support to terrorism, and the company attaches importance to the support of the same view in its commercial partners.
In order to ensure the prompt reporting of suspicious activities related to combating money laundering and terrorism financing to the relevant authorities, the Company provides all requested information and documents in full, either voluntarily or as required by relevant public authorities. This includes ensuring that responses are clear, timely, and comprehensive, reflecting the Company’s commitment to transparency and cooperation. The Company also participates in and complies with the necessary actions and guidance provided in this regard. By maintaining open lines of communication and actively engaging with authorities, the Company demonstrates its dedication to supporting broader efforts to prevent financial crime.
This Policy is regularly reviewed and updated in accordance with changing legal regulations, international standards, and the Company's activities. The relevant update is made by following the latest developments and is carried out in accordance with the latest situation in the sector. These updates are not only based on theoretical sources but are also in line with the determination of standards in practice and compliance with relevant laws. In this regard, policy changes are directly initiated by the Company, and it is the Company's responsibility to announce these changes to both its employees and the public. It is one of the company's priorities to make announcements and trainings regarding changes understandable and on time. In this sense, briefings and trainings can be organized for employees while notifications are made to the public through social media and websites.
This Policy is binding for all units and employees established and operating within the Company, and compliance with the provisions contained herein is essential. It serves as a foundation for maintaining the Company's commitment to integrity, transparency, and legal compliance across all levels of the organization. The board of directors of the Company is solely responsible for ensuring the effective implementation and monitoring of the provisions. By actively overseeing compliance efforts and providing necessary resources, the board ensures that every team member understands their role in upholding the Policy and its objectives.
This Policy is accessible to all employees operating within the Company and the dissemination of this nature is directed by the board of directors of the Company to ensure its implementation. Internal portals, trainings and easily accessible file are utilized to share the Policy in a clear and understandable manner. The announcement is made in accordance with communication procedures exclusively determined by the Company. By leveraging these tailored communication methods, the Company ensures that every employee is fully informed and well equipped to comply with the Policy in their daily responsibilities.
The Company continuously evaluates and measures the effectiveness of the Policy. This ongoing evaluation is central to the Company’s commitment to improvement and ensures that the Policy remains dynamic and responsive to changing conditions. Within the scope of assessment activities aimed at ensuring compliance with national and international standards, particularly in terms of risk reduction and reporting of suspicious activities, internal and external audits, as well as customer feedback data, are taken into consideration. By incorporating diverse sources of feedback and insight, the Company ensures a comprehensive approach to measuring its compliance efforts and addressing potential gaps or areas for improvement.