Anti-Money Laundering Policy

Effective Date: October 14, 2025
Last Updated: October 14, 2025

1. Purpose and Scope

This Anti-Money Laundering Policy (“AML Policy”) aims to ensure that all transactions conducted by PLYR.COM are carried out in compliance with international financial regulations and to 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

Turkey Operations: ZGEN TECHNOLOGY LTD – K.K.T.C. / Gazimağusa Free Port and Zone P.O. Box No: 1344
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 fundamental 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),
Enhancement and continuity of AML awareness among employees.

4. Customer Identification (KYC) Process

Users are identified with verified email and IP information before making payments or conducting transactions.
Additional identity verification may be requested for suspicious or high-value transactions (e.g., submission of ID or invoice).
The company applies advanced risk analysis to prevent the creation of 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 conduct transactions on behalf of another person.

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 behavioral history are assessed individually.

High-risk areas (FATF High-Risk Jurisdictions) are subject to special scrutiny.
Suspicious activities can be evaluated 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 retained for at least 5 years. These records can only be shared with authorized audit institutions.

8. Employee Training and Awareness

PLYR.COM staff are regularly trained on AML and KYC topics. All employees are informed about their obligations regarding the detection and reporting of suspicious transactions.

9. International Compliance

PLYR.COM operates in compliance 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. Governing Law and Jurisdiction

Turkey / TRNC Users: The laws of the TRNC and the Republic of Turkey apply. The competent court is Gazimağusa Courts.
Global Users: The laws of the State of Delaware / New York (USA) apply.

11. Policy Updates

PLYR.COM reserves the right to update this AML Policy as necessary. The current versions become effective 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