Anti-Fraud

1. Introduction

Acus Media OÜ ("Company") operating www.sparkfeet.com ("Platform") is committed to preventing and detecting fraud, human trafficking, and money laundering. This Anti-Money Laundering (AML) and Anti-Fraud Policy outlines the protocols and procedures we have implemented to mitigate these risks.

2. Company Oversight

The company itself has taken the responsibility to oversee the implementation and enforcement of this policy. It ensures compliance with relevant laws and regulations and is in charge of the ongoing training of staff.

3. User Verification

All users (both content creators and customers) must undergo a verification process that includes:

• Submission of a valid government-issued ID.
• Verification of age (must be 18 years or older).
• Verification of identity using biometric data (e.g., a selfie matched with the ID).

An external provider may be used for automated verification.

4. Transaction Monitoring

All transactions on the Platform are monitored using systems designed to detect suspicious activities. The following protocols are in place:

Automated Monitoring:

• All transactions are subject to checks for unusual patterns that may indicate fraud, money laundering, or human trafficking.
• Transactions are flagged if they exceed certain thresholds or exhibit patterns consistent with known fraudulent activity.

Manual Review:

• Transactions flagged by automated systems are subject to manual review by our compliance team.
• The team assesses the flagged transactions to determine if they are genuinely suspicious and require further action.

5. Criteria for Flagging Unusual Transactions

The following criteria are used to flag transactions as unusual:

High-Value Transactions: Single transactions or a series of transactions that exceed predefined thresholds.

Rapid Transactions: Multiple transactions in a short period, especially if they involve large sums.

Geographical Risk: Transactions involving jurisdictions known for high levels of corruption, money laundering, or human trafficking.

Pattern Deviation: Transactions that deviate significantly from a user's normal activity pattern.

Unusual Payment Methods: Use of uncommon or high-risk payment methods (e.g., cryptocurrencies, prepaid cards) - if supported by the Platform and the respective payment provider.

Irregular Account Activity: Sudden changes in transaction volume or frequency without a clear business rationale.

Third-Party Payments: Payments made from accounts not directly associated with the user or content provider.

Layering Transactions: Transactions structured in a way to conceal the source of funds, such as splitting a large amount into smaller sums.

6. Reporting and Record-Keeping

Suspicious Activity Reports (SARs)

• When a transaction is confirmed as suspicious, a SAR is filed with the relevant authorities in Estonia.
• The Company ensures that all SARs are filed promptly and accurately.

Record-Keeping

• All user verification documents, transaction records, and SARs are maintained for a minimum of five years.
• Records are stored securely and are accessible only to authorized personnel.

7. Training and Awareness

• Regular training sessions are conducted for all employees to ensure awareness of AML and anti-fraud protocols.
• Training includes identifying signs of money laundering, human trafficking, and fraud, and procedures for reporting suspicious activities.

8. Ongoing Monitoring and Review

• The AML/Anti-Fraud policy is reviewed annually to ensure it remains effective and compliant with current laws and regulations.
• Continuous improvements are made to our monitoring systems based on emerging threats and technological advancements.

9. Cooperation with Authorities

• The Company cooperates fully with law enforcement and regulatory authorities in investigating and prosecuting any instances of fraud, human trafficking, or money laundering.
• Information is shared with authorities as required by law and in accordance with privacy policies.