AML Policy

1. Purpose and scope

This Anti-Money Laundering Policy ("AML Policy") summarizes the commitments and controls that Omicron Gama S.A. ("Omicron Gama", "we", "us") applies to prevent money laundering, terrorist financing, sanctions evasion and fraud. It is a public statement of our approach, consistent with the Paraguayan legal framework on the prevention of money laundering and terrorist financing (Law No. 1015/1997 and its amendments, and Law No. 6419 on the freezing of financial assets of persons linked to terrorism and to the proliferation of weapons of mass destruction) and with the FATF Recommendations; Omicron Gama's detailed internal procedures are not published. This policy is an integral part of Omicron Gama's Terms and Conditions and applies to every customer.

2. Our business

Omicron Gama is a business-to-business distributor of digital products, such as gift cards, gaming credits and software, and also exports timber products. Omicron Gama acquires digital products for resale to verified business customers. Omicron Gama sells its own commercial inventory; it does not hold funds on behalf of third parties and does not transfer money on behalf of customers. This policy applies to all of Omicron Gama's business relationships, including those of its timber export activity.

3. Risk-based approach

Omicron Gama applies a risk-based approach: it assesses the money laundering and terrorist financing risks to which it is exposed and applies controls proportionate to those risks. This allows Omicron Gama to focus its resources and to take enhanced measures in higher-risk situations.

4. Customer due diligence

Every customer must complete the verification procedure set out in our KYC/KYB Policy before Omicron Gama starts a business relationship. This includes the identification and verification of the customer, its beneficial owners and its authorized representatives, and an understanding of the purpose of the relationship.

Omicron Gama applies heightened scrutiny to customers who are residents of countries identified by credible sources as having inadequate anti-money laundering standards or as presenting a high risk of crime and corruption, and to beneficial owners who reside in, or whose funds originate from, such countries. Omicron Gama does not establish business relationships with persons located or resident in jurisdictions identified by the FATF as high-risk jurisdictions subject to a call for action or subject to comprehensive sanctions, such as Iran and North Korea, or in the territories of Ukraine occupied by Russia.

5. Sanctions

Omicron Gama does not knowingly do business with persons or entities subject to sanctions imposed by the United Nations Security Council, the Republic of Paraguay, the United States, the European Union, the United Kingdom or other competent authorities, or with persons acting on their behalf. Customers are screened against sanctions information, and Omicron Gama may reject, block, suspend or cancel transactions when there is a reasonable risk of a sanctions violation.

6. Monitoring of activity

In addition to gathering information from customers, Omicron Gama monitors customer activity to identify unusual transactions. An unusual transaction is one that is inconsistent with legitimate business or with the customer's known transaction history. Unusual activity is reviewed and escalated internally when appropriate, and additional controls are applied when the risk requires it.

7. Limits, restriction and suspension

Omicron Gama applies limits and restrictions according to each customer's profile and access level. Omicron Gama reserves the right to restrict or suspend any customer's activity that it considers to pose a risk of illegal activity or money laundering.

8. Third-party verification

To carry out verification and background checks, Omicron Gama may make inquiries, directly or through third-party service providers, as necessary to verify identity and to prevent fraud, misidentification, money laundering or any other prohibited activity. Omicron Gama may take the actions it considers necessary based on the results of these inquiries.

9. Record keeping

Omicron Gama keeps records of transaction data and of the data and documents obtained for identification purposes, as well as documentation of its anti-money laundering reviews, for at least five (5) years after the end of the business relationship, or longer where required by law.

10. Cooperation with competent authorities

Omicron Gama cooperates with regulators and law enforcement authorities where required by applicable law, and may provide information in response to valid legal requests.

11. Customer obligations

Customers must provide accurate and complete information, keep it up to date, cooperate with verification requests and not use Omicron Gama's services for any unlawful purpose, as set out in the Terms and Conditions.

12. Changes and contact

Omicron Gama may update this policy to reflect changes in its processes or in applicable law. The English version is the master version and prevails in the event of any inconsistency. For questions about this policy, contact [email protected].