AML / MASAK Compliance Policy

1. Purpose

This AML (Anti-Money Laundering) Policy has been adopted by knightpin.com (Alpysky Oyun Yazılım ve Teknoloji A.Ş.) within the framework of Law No. 5549, the regulations of MASAK of the Republic of Türkiye and the FATF Recommendations, in order to prevent the laundering of proceeds of crime, the financing of terrorism, fraud and other financial crimes.

2. Core principles

• Zero tolerance: The Company applies a zero-tolerance policy in combating money laundering.
• Risk-based approach: Risk is assessed by customer, product, transaction and geography.
• Transparency and accountability: All processes are recorded and reported to the competent authorities where required.
• Awareness: Staff are kept informed of changes in legislation and risks.

3. Risk assessment

Transactions are classified as low, medium or high risk according to the following criteria:

• Transaction amount (₺75,000 and above is subject to enhanced review),
• The customer's history and previous behavior,
• Geography (high-risk country lists),
• Transaction pattern (unusual frequency, amount, time of day),
• Transactions made on behalf of third parties,
• Attempts at anonymization (VPN, virtual identity, fake address).

4. Transaction monitoring

Transactions are monitored using automated rules and manual review. The following are tracked in particular:

• Attempts to split transactions below thresholds (smurfing),
• Single or linked transactions of ₺75,000 or more,
• Transactions where the card, IBAN and IP do not match,
• Activity from multiple accounts on the same IP,
• Rapid balance top-up and withdrawal cycles.

5. Know Your Customer (KYC) practice

The KYC processes, a core component of the AML policy, are explained in detail on the "KYC Policy" page. Additional verification (enhanced due diligence) is applied to high-risk customers.

6. Suspicious transaction reporting

Transactions that appear suspicious are reported to the Financial Crimes Investigation Board (MASAK) of the Ministry of Treasury and Finance of the Republic of Türkiye and, where necessary, to other competent authorities, regardless of the amount. The customer is not informed of the report.

7. Sanctions list screening

At the identity verification stage and, where necessary, at the transaction and withdrawal stages, customer information is checked against the lists of the UN Security Council, the European Union, OFAC and the Republic of Türkiye. If a match is found, the transaction is rejected and the case is reported to the competent authorities.

8. Prohibited activities

• Attempting to launder money from illegal sources,
• Transactions made on behalf of a third party where this is concealed,
• Transactions made with a fake identity or through identity theft,
• Use of stolen or fake payment methods,
• Creating money cycles using fake game accounts,
• Transactions with persons on sanctions lists.

9. Compliance Officer

A Compliance Officer responsible for implementing this policy has been designated within the Company. The Compliance Officer is responsible for monitoring, reporting, record management and keeping track of legislation.

10. Record retention

Identity verification documents, transaction records and suspicious transaction report files are stored securely for at least 8 years.

11. Staff training

Staff who review transactions are informed about AML/CFT legislation, detecting suspicious transactions, fraud patterns and data security.

12. Review

AML/CFT processes are reviewed at least once a year; the risks and shortcomings identified are reported to the Board of Directors and improvement plans are implemented.

13. Contact

For AML compliance processes and suspicious transaction reports, contact: [email protected]