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. 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. Subsequently, the Company reviews and updates the Policy accordingly.
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. 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 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 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. 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. 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. 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 Company regularly reviews and updates its customer acceptance policy and procedures in line with changing legal regulations, international standards, and its operations. Information and documents related to customers are kept by the Company and are presented to relevant public authorities upon request.
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. 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. 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.
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. Additionally, the Company consents to inspections related to this matter conducted by relevant public authorities or independent institutions and organizations.
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. The Company does not establish any business relationship without verifying the stated information.
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. The Company also participates in and complies with the necessary actions and guidance provided in this regard.
This Policy is regularly reviewed and updated in accordance with changing legal regulations, international standards, and the Company's activities. 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.
This Policy is binding for all units and employees established and operating within the Company, and compliance with the provisions contained herein is essential. The board of directors of the Company is solely responsible for ensuring the effective implementation and monitoring of the provisions.
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. The announcement is made in accordance with communication procedures exclusively determined by the Company.
The Company continuously evaluates and measures the effectiveness of the Policy. 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.