Anti-Money Laundering Policy

Effective Date: October 14, 2025
Last Updated: June 23, 2026

1. Purpose and Scope

This Anti-Money Laundering Policy (“AML Policy”) aims to ensure that all transactions conducted by PLYR.COM comply with international financial regulations and prevent illegal fund movements.

The policy is prepared based on compliance with FATF (Financial Action Task Force), European Union AML Directives, US OFAC sanctions, MASAK, and other international regulations.

2. Company Information

• Global Operations: ZGEN TECHNOLOGY LLC – 169 Madison Ave STE 11534 Unit 185, New York, NY 10016, USA

Contact: [email protected]

3. AML Policy Principles

PLYR.COM adheres to the following core AML principles:

• Verification of user identities (KYC – Know Your Customer),
• Detection and reporting of suspicious transactions,
• Risk-based approach,
• Data privacy and security,
• Compliance with international sanction lists (OFAC, UN, EU),
• Raising and maintaining AML awareness among employees.

4. Customer Identification (KYC) Process

• Users are identified with verified email and IP information before making payments or transactions.
• Additional identity verification may be requested for suspicious or high-value transactions (e.g., ID or invoice submission).
• The company applies advanced risk analysis to prevent fake or anonymous accounts.
• Accounts may be suspended if multiple account creation, IP manipulation, or proxy/VPN usage is detected.

5. Suspicious Transaction Monitoring and Reporting

PLYR.COM monitors suspicious transaction activities through automated systems and manual audits.

• Multiple high-value transactions in a short period,
• Repeated payment attempts from different countries,
• Unusual frequency of refund requests,
• Anonymous or non-compliant payment methods,
• Attempts to transact on behalf of others.

If a suspicious transaction is detected, the account is temporarily frozen and relevant legal authorities (e.g., MASAK, OFAC, FATF) may be notified.

6. Risk Management

The company adopts a risk-based AML approach. Each user's transaction volume, country risk, payment method, and behavior history are evaluated individually.

• High-risk regions (FATF High-Risk Jurisdictions) are subject to special review.
• Suspicious activities may be assessed regardless of transaction volume.
• The company may apply transaction limits and restrictions to minimize financial risks.

7. Record Keeping and Retention

All user records, payment history, and verification data are securely stored for at least 5 years. These records are only shared with authorized audit institutions.

8. Employee Training and Awareness

PLYR.COM staff receive regular training on AML and KYC topics. All employees are informed about their obligations regarding suspicious transaction detection and reporting.

9. International Compliance

PLYR.COM operates in accordance with the following international regulations and principles:

• FATF Recommendations (Financial Action Task Force)
• EU 4th, 5th, and 6th AML Directives
• US Bank Secrecy Act (BSA) and OFAC Sanctions
• MASAK Guidelines (Republic of Turkey Financial Crimes Investigation Board)

10. Applicable Law and Jurisdiction

• Global Users: Laws of Delaware / New York State (USA) apply.

11. Policy Updates

PLYR.COM reserves the right to update this AML Policy as needed. Updated versions take effect as soon as they are published at https://plyr.com/page/aml-policy.

12. Contact

For communication regarding AML and financial compliance:
Email: [email protected]
Web: https://plyr.com