Anti-Money Laundering Policy

1. Purpose and Scope

SOLFIRE is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines our procedures and controls to detect, prevent, and report suspicious activities in compliance with applicable international regulations including the Financial Action Task Force (FATF) recommendations.

This policy applies to all users of the SOLFIRE platform, all employees and contractors, and all transactions processed through the platform.

2. Risk Assessment Framework

We conduct ongoing risk assessments of our platform operations, categorizing risks by:

• Customer Risk: Assessment based on wallet activity history, transaction patterns, and behavioral indicators
• Geographic Risk: Heightened scrutiny for transactions involving high-risk jurisdictions as identified by FATF
• Product Risk: Evaluation of inherent risks in different game types and transaction channels
• Transaction Risk: Monitoring of transaction size, frequency, and patterns that may indicate suspicious activity

Our risk-based approach ensures that resources are focused on the highest-risk areas while maintaining proportionate controls across all operations.

3. Customer Due Diligence (CDD)

While SOLFIRE operates on a decentralized model with wallet-based authentication, we implement the following due diligence measures:

Standard Due Diligence

• Blockchain analytics to screen wallet addresses against known sanctioned, flagged, and illicit addresses
• Automated monitoring of transaction patterns for suspicious activity
• Cross-referencing wallet addresses with publicly available intelligence sources
• Monitoring of betting patterns for irregularities

Enhanced Due Diligence (EDD)

Enhanced due diligence is applied when:

• Cumulative deposits or withdrawals exceed 10 SOL within a 24-hour period
• Cumulative transactions exceed 100 SOL within a 30-day period
• Wallets associated with known mixing services, tornado-style protocols, or privacy coins
• Transaction patterns match known money laundering typologies
• The customer is from or transacting with a high-risk jurisdiction

EDD measures may include: requesting identity verification, requiring source of funds documentation, imposing transaction limits, or suspending account access pending review.

4. Transaction Monitoring

We employ automated monitoring systems that flag the following patterns:

• Rapid pass-through: Deposits followed by immediate or near-immediate withdrawals with minimal gameplay
• Structuring: Multiple transactions designed to stay below reporting thresholds
• Coordinated activity: Multiple wallets operating in synchronized patterns suggesting common control
• Sanctioned addresses: Transactions involving wallets flagged by OFAC, EU, or UN sanctions
• High-risk interactions: Interactions with known illicit addresses, mixing services, or darknet-associated wallets
• Unusual volume: Transaction volumes significantly above the user's established pattern
• Round-trip transactions: Funds cycling between the platform and external wallets without apparent legitimate purpose

5. Large Transaction Thresholds

The following thresholds trigger additional review and potential reporting:

6. Suspicious Activity Reporting (SAR)

When suspicious activity is detected, we follow a structured investigation and reporting process:

1. Detection: Automated systems flag suspicious patterns or compliance team identifies concerns
2. Investigation: Compliance team reviews the flagged activity, gathering all relevant transaction data
3. Action: Based on the investigation, we may:
   • Temporarily suspend the associated wallet's access
   • Request additional verification or documentation
   • Restrict transaction limits
   • Permanently ban the associated wallet
4. Reporting: File suspicious activity reports (SARs) with relevant financial intelligence units (FIUs) and law enforcement as required by applicable law
5. Record keeping: Maintain complete records of the investigation, decision, and any reports filed

7. Source of Funds Policy

Where enhanced due diligence is triggered, we may request evidence of the legitimate source of funds. Acceptable sources include but are not limited to:

• Employment income (pay stubs, employment contract)
• Business income (business registration, financial statements)
• Investment returns (brokerage statements, exchange records)
• Inheritance or gifts (legal documentation)
• Cryptocurrency trading (exchange history, trading records)

Users who fail to provide adequate source of funds documentation within 14 days may have their account restricted until compliance is achieved.

8. Sanctions Compliance

We screen all wallet addresses against international sanctions lists including:

• OFAC Specially Designated Nationals (SDN) list
• European Union Consolidated Sanctions list
• United Nations Security Council Sanctions list
• FATF high-risk and non-cooperative jurisdictions list

Wallets associated with sanctioned entities or jurisdictions are blocked from using the platform. Screening is performed at onboarding and periodically thereafter.

9. Record Keeping

In compliance with regulatory requirements, we maintain comprehensive records:

• Transaction records: All deposits, withdrawals, bets, and payouts are recorded on the Solana blockchain (immutable) and in our internal database. Retained for a minimum of 7 years.
• Due diligence records: All CDD and EDD documentation, including identity verification data. Retained for a minimum of 7 years after the business relationship ends.
• Investigation records: All internal investigations, suspicious activity reports, and correspondence with authorities. Retained for a minimum of 7 years.
• Communication records: Relevant communications with users regarding compliance matters. Retained for a minimum of 5 years.

10. Staff Training and Compliance

Our team receives regular AML/CTF training covering:

• Current AML/CTF regulations and compliance obligations
• Cryptocurrency-specific money laundering typologies
• Identifying and escalating suspicious activity
• Sanctions screening procedures
• Record keeping and data protection requirements
• Updates to regulatory requirements and industry best practices

Training is conducted at onboarding and refreshed annually, with additional sessions when material regulatory changes occur.

11. Cooperation with Law Enforcement

SOLFIRE cooperates fully with law enforcement agencies and regulatory bodies in the investigation of suspected financial crimes. We will comply with lawful requests for information, court orders, and subpoenas. We do not tip off users who are subject to investigation.

12. Contact

To report suspicious activity or for AML-related inquiries, please contact our compliance team through our official Discord server or Telegram channel. All reports are treated confidentially and investigated thoroughly.