1. The trading of virtual resources that have no physical form, due to the anonymity of users, unregistered trading of virtual resources, and the value of these resources, which have a specific financial dimension and in some situations represent significant assets, may serve as a means of transferring goods of criminal origin.

2. The risk of possible crimes stems largely from the basic characteristics of virtual assets, which are:

   1. Digital version of resources – virtual resources have no physical form and exist only in the form of digital records. This results in the following characteristics, listed below:

   2. Easy transfer of resources – virtual resources can be transferred relatively easily, including through sale, organizing a so-called battle for virtual resources, as well as exchange using an “exchanger” tool. This also facilitates the transfer of value associated with virtual resources;

   3. Possibility of anonymous transfers – virtual resources belong to entities that have accounts on the website. These, in turn, do not have to be linked to real identities in any way;

   4. Service availability – anyone can carry out transactions, and without the introduction of KYC regulations, it may be difficult to identify users trading in virtual assets;

   5. High mobility – trading virtual resources has no territorial restrictions; these items can be sold to different people from different places without the need for physical transport, storage, or control by state authorities.

   6. Subjective valuation – the value of virtual assets is often determined based on the specific characteristics of the items, but the valuation of these items is subjective. Unlike physical assets, it does not depend on the quality or condition of the asset in question. Virtual assets can be traded in any way.

3. All of the above characteristics mean that services related to the trading of virtual assets may be vulnerable to criminal activity, mainly money laundering, due to the possibility of transferring funds from dubious sources, unless the risk in question is adequately mitigated by the introduction of appropriate practices and internal regulations, which is the purpose of introducing these solutions.

1. Trading in virtual resources that do not have a physical form on the website www.g4skins.com (referred to in the regulations as “items”) is not free from the risk of the services provided being used for money laundering, terrorist financing, fraud, tax offenses, and other crimes (hereinafter also referred to as “crimes”).

2. In order to prevent the use of the website for criminal activities, including mitigating the risk of money laundering and terrorist financing, as well as for fiscal purposes, internal policies are introduced related to user identification, verification of user data, sources of origin of assets that users engage in trading virtual resources, selective analysis of user activity, and possible scenarios in which the service may be used for criminal purposes.

3. In view of the above, in the course of establishing a relationship with the user and during ongoing cooperation, the website administrator may request that the user provide information, data, and documents in order to:

   1. User identification consisting in determining user data, including first name, last name, identification number, citizenship, date and place of birth, and place of residence;

   2. Identification of the user's beneficial owners, in a situation where the user acts on behalf of third parties or involves the assets of other entities in the service. In this case, the service administrator may identify and verify the beneficial owners on whose behalf the user acts;

   3. User verification consisting of confirming the customer's identity, including confirmation of the user's identified data;

   4. To evaluate the relationship with the user, including determining the value of current or anticipated trading in virtual resources, typical behavior and transfer of assets by the user, and the typical model of use of the service;

   5. Analysis of the website user's behavior in terms of unusual circumstances, including those contrary to the findings made in relation to point 4 above, as well as analysis of the user's activity from the perspective of the rationality of their behavior (e.g., whether the user deliberately enters into transactions that are economically disadvantageous to them), analysis of the customer's resources in relation to their economic situation;

   6. In justified cases, where the user's activity may justify suspicion of using the website for criminal purposes, the website administrator may request documents confirming the source of the assets involved in the user's activity on the website, including for the purposes of analyzing the user's behavior;

   7. Determining the user's presence on sanctions lists and linking the user's assets to the avoidance of sanctions policy, as well as identifying persons with PEP/RCA status (politically exposed persons and entities associated with them);

   8. Updating data, information, and documents concerning the user and their activity on the website. In the case of users identified as high risk, updates are performed more frequently, at least once a year.

4. The website administrator appoints appropriate persons with access rights to the personal data of website users to perform the above activities. To obtain, collect, process, and store user data, the Administrator may use the samsub website software (https://sumsub.com/) or perform verification via e-mail correspondence (in particular, by the User providing the required information or documents to the address indicated by the Administrator). The choice of verification method, scope, and channel is exclusively up to the Administrator. The sumsub website is a reliable service provider in this regard. The use of sumsub website tools allows for the automation of website user verification processes, which involves the optimization and adaptation of these processes to market standards.

5. All information, data, and documents provided by the user are protected in a manner that ensures security against loss or unauthorized access, in accordance with the internal policies and procedures implemented and generally applicable law.

1. When analyzing user behavior, the following user behavior is taken into account and is unacceptable to the website administrator:

   1. attempts to conceal identity, use of outdated, false, or someone else's documents;

   2. acting on behalf of or for third parties or using the economic resources of such entities, both with their consent and in situations where such consent has not been given;

   3. use of payment methods or forms belonging to third parties and refusal to prove ownership of a given form of payment or payment instruments (e.g., use of a debit or credit card, third-party payment account);

   4. exploiting technical faults in the website;

   5. creating and using multiple accounts by a single user, in a situation where this is not justified by circumstances related to the customer in question (without a clear reason);

   6. violations of the rules, policies, and procedures governing the operation of the website;

   7. introduction of assets that do not have a legal source or translation into the user's income;

   8. using virtual resources as a means of investing assets of criminal origin and as a means of storing and transferring value (trading in virtual resources within the service is for the purpose of entertainment and is not intended to create alternative means of storing and transferring value);

   9. consolidating the practice of withdrawing virtual resources immediately after receiving them, which may indicate that the service is being used as a tool for converting and transferring assets, and that the user's activity is not aimed solely at satisfying entertainment needs.

2. In the case of justified suspicion or detection that the user's activity falls within the above scenarios (situations that may indicate an increased risk of crime), violates generally applicable laws or internal regulations of the website, the user (by accepting the website's terms and conditions) gives their express consent, and the website administrator may:

   1. Refuse to execute or suspend the processing of specific transactions or all transactions;

   2. Block or restrict access to the user's account, virtual resources, account balance, and tools enabling the trading or transfer of virtual resources outside the service;

   3. Initiate proceedings related to determining the user's situation, including by updating the user's KYC, obtaining additional explanations and documents;

   4. Refuse to provide services delivered through the website;

   5. Notify the relevant bodies, including law enforcement agencies, of a reasonable suspicion that a user has committed a crime, based on credible evidence that gives rise to such suspicion.

3. In the event of contact with the website administrator by representatives of public administration or law enforcement agencies, please refer to the tab “Information for services, government agencies, and law enforcement agencies.”

4. In a situation involving a block, restriction of access to the user's account, virtual resources, account balance, and tools enabling the trading or transfer of virtual resources outside the service, in order to proceed with the removal of restrictions, the user is required to provide the data, information, and documents specified by the service administrator.

5. If the requested data, information, and documents are not provided, the website administrator is entitled to terminate the process of establishing a business relationship, refuse to establish cooperation, or terminate an existing legal relationship without restoring the user's ability to use the website's services, including temporarily. In such a case, the website administrator will consider whether the failure to provide the requested information, data, and documents constitutes grounds for notifying the relevant authorities.

6. The website administrator may retain the values received from the user and the virtual resources held by them until appropriate instructions are given by law enforcement or government authorities.

The website administrator shall not be liable or bear any economic risk for actions taken to ensure the enforcement of generally applicable laws against crime and to support public administration and law enforcement authorities in this regard. The website administrator is not liable for any damage incurred by the user as a result of the above actions, and the user declares that they are aware of the possible risks and expresses their willingness to cooperate with the website administrator in this regard, including by actively providing the necessary materials, and undertakes not to make any claims against the website administrator in connection with the performance of the above obligations.

If users of the website discover transactions that may be connected with money laundering, terrorist financing, fraud, tax crimes, or other crimes, reports should be sent to the following email address: legal@g4skins.com.