Anti-Money Laundering Policy

This Policy establishes the principles and internal procedures implemented by GameValues Ltd to prevent the use of the platform and its services for money laundering, terrorist financing or other illegal financial activities.

GameValues Ltd operates the online platform https://rmt.games, which provides users with technological infrastructure for secure and transparent P2P transactions — the buying, selling and exchange of virtual gaming assets. The Company does not hold, manage or own user assets, and does not act as a financial intermediary.

This Policy applies to all directors, employees, contractors and partners of GameValues Ltd, as well as to users classified as sellers or high-volume participants.

GameValues Ltd operates in accordance with the legislation of the Republic of Cyprus and is guided by:

• The Prevention and Suppression of Money Laundering and Terrorist Financing Law (Cyprus);

• EU Directive 2015/849 (Fourth EU AML Directive) and subsequent amendments;

• Recommendations of CySEC and the European Banking Authority;

• EU Regulation 2016/679 (GDPR) — with regard to personal data protection.

GameValues Ltd applies a risk-based approach:

• low-risk users (buyers, standard players) transact without mandatory KYC;

• medium and high-risk users (sellers, large volumes, suspicious activity) undergo selective identity verification;

• the monitoring system automatically tracks anomalous or repetitive transactions.

Selective identity verification is conducted in cases where:

• a user lists items as a seller;

• trading volume exceeds EUR 1,000 over 30 days;

• unusual activity has been identified (multiple wallets, chargebacks, use of anonymous coins);

• a request has been received from a partner or regulator.

Verification may include:

• identity document;

• liveness check and facial matching;

• proof of residential address.

The ShuftyPro system is used for verification, applied to UBOs and individual users where necessary.

The Company conducts automated and manual monitoring to detect:

• suspicious transactions and limit circumvention;

• rapid movement of assets between connected accounts;

• use of stolen or blocked credentials.

Identified cases are referred to the Compliance Officer for analysis. Upon confirmation of suspicion, information may be submitted to MOKAS (the Cyprus Anti-Money Laundering Unit) or other competent authorities.

All identified suspicious activities are recorded in an internal log (SAR Log). Each entry includes the date, user identifier, nature of the incident and actions taken. The Compliance Officer reviews each report and decides whether to block, suspend the operation or notify regulatory authorities.

GameValues Ltd conducts, where necessary:

• screening of users against international sanctions lists (EU, UN, OFAC);

• checks for Politically Exposed Person (PEP) status through the integrated KYC provider.

Such checks are performed selectively — for sellers, large transactions and at the request of payment partners.

The platform accepts cryptocurrency deposits. Where necessary, basic wallet analysis and source of funds assessment may be conducted using third-party blockchain monitoring tools. Such checks are performed selectively — in cases of anomalous activity or at the request of payment systems.

AML-related materials are retained for a minimum of 5 years, including:

• data of verified users;

• transaction history;

• internal reports and AML incident correspondence.

Information is protected by technical and organisational measures and processed in accordance with the GDPR. Access is restricted to authorised employees only.

Compliance Officer: Roman Kuzmin, Managing Director, GameValues Ltd

Responsibilities:

• implementation and oversight of policy compliance;

• interaction with payment and verification organisations;

• analysis of suspicious operations and decision-making on account blocks.

Technical and Analytical Department:

• implements monitoring algorithms and risk assessment;

• tracks transactions and prevents circumvention of restrictions.

Employees and contractors with access to user data undergo basic AML training, including:

• recognition of suspicious activity;

• internal notification and escalation procedures;

• data protection and confidentiality rules.

The Policy is reviewed annually or earlier — upon changes in legislation, partner requirements or the business model. Amendments are approved by the Compliance Officer and take effect after internal update.