Skinworld

SkinWorld is a brand name of PIXELGATE GROUP LTD, registration number HE 418476, having it's registered address at Kalymnos, 1, "Q MERITO", Floor 4, Agios Nikolaos, Kamares, 6037, Larnaca, Cyprus.

This policy establishes the general framework within which SkinWorld combats anti-money laundering and related fraudulent activity in relation to https://skinworld.gg. SkinWorld has implemented reasonable measures to prevent fraudulent activity from happening on its website and to comply with anti-money laundering legislation.

The AML program of SkinWorld is designed to be compliant with:

• ▪ EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”;
• ▪ EU: “Regulation 2015/847 on information accompanying transfers of funds”;
• ▪ EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods; and
• ▪ BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash.

Money Laundering means:

• ▪ The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;
• ▪ The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;
• ▪ The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;
• ▪ Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points (a), (b) and (c).

Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

In accordance with the applicable legislation, SkinWorld applies the “highest level” of money laundering protection, being D Level Management (Company Management). In addition, an AMLCO (Anti Money Laundering Compliance Officer) is responsible for the enforcement of this policy and procedures for SkinWorld. The AMLCO is placed under the direct responsibility of the Chief Executive Officer.

Any significant change to this policy is subject to approval by the SkinWorld, D Level Management.

As part of our risk-based approach, SkinWorld has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to SkinWorld and its business lines. The SkinWorld AML risk policy is determined after identifying and documenting the risks inherent to its business lines, such as:

• ▪ the products and services the website offers
• ▪ the customers to whom such products and services are offered
• ▪ transactions performed by these customers
• ▪ delivery channels used by the bank
• ▪ the geographic locations of the bank’s operations
• ▪ customers; and
• ▪ transactions and other qualitative and emerging risks

The identification of AML risk categories is based on SkinWorld’s understanding of regulatory requirements, regulatory expectations and industry guidance.

The EWRA is reassessed annually.

SkinWorld has established standards regarding Know-Your-Customer (“KYC”). These standards require due diligence on each risk-associated customer before providing the ability to receive items as offered on SkinWorld. The due diligence process requires identification and verification of a user’s identity and their representatives and/or beneficial owners on the basis of documents, data or information obtained from a reliable and independent source compliant with the domestic and European AML legislation and regulation.

Interpretation of the KYC principle begins with identification of the customer by means of the necessary identification documents.

All geographical and user-provided data we obtain enables the Customer Acceptance Policy to be applied. In addition to these objective criteria, there are subjective elements which may arouse suspicions regarding a customer and to which particular attention should be paid.

As KYC does not involve static data, but dynamic data through the relationship with the customer, it also needs follow-up and ongoing monitoring of the customer.

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on us establishing the validity of the following items:

• ▪ A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning https://skinworld.gg Please note that all four corners of the ID have to be visible in the same image and all details have to be readable.
• ▪ Proof of address, in the form of a recent utility bill sent to your registered address, bank statement or any governmental post addressed to you within the last 3 months.

To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document are visible and all text is readable.

AML compliance ensures that ongoing transaction monitoring is conducted to detect transactions which are unusual or suspicious compared to the customer profile. This transaction monitoring is conducted on two levels:

1) The first line of control:

SkinWorld works solely with trusted Payment Service Providers whom all have effective AML policies in place to prevent the large majority of suspicious deposits onto SkinWorld from taking place without proper execution of KYC procedures.

2) The second line of control:

SkinWorld will implement its own KYC procedures based on a risk assessment of ongoing transactions on the site. This due diligence could be conducted in relation to:

• ▪ Requests for the execution of financial transactions on the account;
• ▪ Requests in relation to means of payment or services on the account.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behavior and the counterparty to the transaction.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).

3) The third line of control:

The third line of control includes a more structural approach for progressively due diligence procedures, such as the limitation of cash deposits applicable for a specific category of customer.

In its internal procedures, SkinWorld provides guidance to its staff on when it is necessary to report atypical activity and how to proceed with such reporting. Reports of atypical activity are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended. Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

SkinWorld has developed training and awareness programs in order to make its staff aware of their AML duties. The training and awareness program includes:

• ▪ A mandatory AML training program in accordance with the latest regulatory environment;
• ▪ Academic AML training sessions for all new employees; and
• ▪ Training sessions are delivered by an AML-specialist.