Customer Acceptance Policy
1. Introduction
1.1.
In order to safeguard the Company’s reputation, we have a zero tolerance to any financial crime of other illegal activity. We will not accept any customers who are directly or indirectly engaging in any illegal activity. In view of this the Company undertakes different levels of due diligence to ensure that its customers are reputable.
1.2.
Before opening an account with IZI Interactive Limited (Ltd) we must verify your identity and ensure that you are not known for any financial criminal activity or banned from the gaming industry. Therefore, IZI Interactive Ltd will take into account all factors relating to your activity prior to accepting you as its customer.
1.3.
This policy is important for us as we can determine whether to authorize you to open an account with us. To determine this, we must perform the necessary due diligence by requesting several information and documentation from you.
1.4.
The objectives of this policy are:
1.4.1.
to establish an explicit criterion to allow the opening of an account;
1.4.2.
to ensure that IZI Interactive Ltd has taken all the required measures and has regulated and safeguarded its legal position;
1.4.3.
to minimize anti-money laundering risks.
1.5.
This policy is to be read in conjunction with all the other policies issued by IZI Interactive Ltd as may be updated from time to time.
1.6.
We reserve the right to make changes to this policy at any time. We will ensure that any significant changes made will be notified to you in advance by an appropriate method. From time to time, we reserve the right to request from you any updated documentation that may become necessary or which has become outdated. Your failure to provide us with such documentation may restrict your access to your account until such documentation is provided. Furthermore, if you remain in default of your obligation to provide us with the necessary documentation, we shall have the right to suspend or close your account.
2. Who will IZI Interactive Ltd accept as a customer?
2.1.
Interactive Ltd will do business with you, only if you:
2.1.1.
are a natural person (IZI Interactive Ltd does not accept companies or any other legal entities as customers);
2.1.2.
have read and agreed to the most recent applicable terms and conditions (including any applicable privacy policy, responsible social gameplay policy and this customer acceptance policy) (Terms and Conditions);
2.1.3.
always comply with such Terms and Conditions;
2.1.4.
register with and transact on any IZI Interactive Ltd platform on your own behalf;
2.1.5.
use payment mediums for which you are the legal and beneficial owner;
2.1.6.
are over the age of 18 years;
2.1.7.
reside in Malta and other prohibited jurisdictions;
2.1.8.
are satisfactorily identified and verified under IZI Interactive Ltd's anti-financial crime programme and anti-money laundering policy;
2.1.9.
satisfy IZI Interactive Ltd's due diligence measures (as applicable) including source of wealth and source of funds checks;
2.1.10.
provide information and documents as requested by IZI Interactive Ltd, in accordance with IZI Interactive Ltd's anti-financial crime programme;
2.1.11.
are not:
2.1.11.1.
a politically exposed person (past or present) - PEP*;
2.1.11.2.
a family member or close associate of a PEP**;
2.1.11.3.
named on any sanctions list issued by the United Nations, the European Union, the United Kingdom, the United States, Canada, Australia or any other sanctions list which IZI Interactive Ltd deems appropriate to adhere to from time to time;
2.1.11.4.
directly or indirectly linked to countries or territories subject to comprehensive sanctions;
2.1.11.5.
an individual with a risk profile falling outside of IZI Interactive Ltd's risk tolerance as determined in IZI Interactive Ltd's sole discretion.
2.1.11.6.
Customers unwilling to or who refuse to comply with the requirements and/or do not submit (within the stipulate time frame) all the required information and/or documentation asked, for any reason whatsoever;
2.1.11.7.
Customers who submit false details and/or forged documentation, which includes customers who have fictitious or unreal names;
2.1.11.8.
Customer of unknown identity or where there are no means to ensure that the customer is who he/she states to be;
2.1.11.9.
Same identifiable customers (through different email address and/or ID no) who try to create more than one (1) account to circumvent the application of customer due diligence;
2.1.11.10.
Prior to onboarding customers, where there are any grounds giving rise to suspicion, or knowledge of ML/FT, and/or where there is negative publicity implicating the customer with terrorism or organisations linked to terrorism and/or where the customer has links to one or more jurisdictions or areas where terrorists are active or which are known to sympathise and support terrorists and terrorist organisations.
2.2.
If you are accepted as a customer, IZI Interactive Ltd may ask you to give additional information if IZI Interactive Ltd either:
2.2.1.
classifies you as high risk;
2.2.2.
or deems the additional information necessary from time to time.
Note:
(PEP *) Situations involving so-called ‘Politically Exposed Persons (“PEPs”) require the application of EDD measures, independently of the outcome of the customer risk assessment. This entails having to determine whether a customer is a PEP or otherwise and, should this be the case, apply the following pre-established EDD measures:
- Obtain senior management approval to service the PEP.
- Establish what is their source of wealth and, where applicable, their source of funds.
- Conduct enhanced on-going monitoring of the customer’s activity.
Measures are to be implemented at any point in time between the establishment of the business relationship and the point in time when the €2,000 threshold is met but not later than the lapse of thirty days from when the said threshold is reached. In the case of an occasional transaction, the said measures are required to be carried out, in so far as they are applicable, prior to carrying out the transaction in question.
(PEP **) Situations involving so-called family members of 'Politically Exposed Persons ("PEPs") require the application of CDD measures, independently of the outcome of the customer risk assessment. This entails having to determine whether a customer is a family member of a PEP or otherwise and, should this be the case, apply the following pre-established EDD measures:
- Establish what is their source of wealth and, where applicable, their source of funds.
- Conduct enhanced on-going monitoring of the customer's activity.
Measures are to be implemented at any point in time between the establishment of the business relationship and the point in time when the €2,000 threshold is met but not later than the lapse of thirty days from when the said threshold is reached. In the case of an occasional transaction, the said measures are required to be carried out, in so far as they are applicable, prior to carrying out the transaction in question.
3. What makes IZI Interactive Ltd classify a customer as high risk?
3.1.
IZI Interactive Ltd continually screens accepted customer information, purchases, redemptions, game activity and behaviour for relevant financial crime risk indicators. Depending on the specific facts and context, customers will be classified as having a low, medium or high risk level. IZI Interactive Ltd will classify a customer as high risk where they present or are likely to present money laundering, funding of terrorism or other financial crime risk in accordance with the applicable rules and regulations.
3.2.
While IZI Interactive Ltd seeks to investigate any financial crime risk alerts within a reasonable timeframe, compliance with applicable laws may result in delays while additional due diligence is conducted and relevant information obtained.
4. What additional information will IZI Interactive Ltd request?
4.1.
If IZI Interactive Ltd. classifies you as high risk or determines that additional information is required, you may be asked to provide information on, or evidence of, your:
4.1.1.
income-generating activities;
4.1.2.
estimated net worth or sources of wealth;
4.1.3.
identity attributes in question including but not limited to name, date of birth and address.
4.2.
If you fail or refuse to submit, within the timeframe communicated by IZI Interactive Ltd, the required information, IZI Interactive Ltd. reserves the right to terminate the business relationship with you and close your account.
5.Why is such procedure required?
5.1.
IZI Interactive Ltd. is required to maintain an anti-financial crime compliance programme which includes assessing the level of financial crime risk presented by its customers and accepting only those customers whom it assesses as having an acceptable level of risk. This requirement is set by:
5.1.1.
the laws applicable to IZI Interactive Ltd;
5.1.2.
its third party service providers;
6. What are the key aspects of IZI Interactive Ltd's anti-financial crime programme?
6.1.
The key aspects of IZI Interactive Ltd.'s anti-financial crime programme include but are not limited to:
6.1.1.
the appointment of a Money Laundering Reporting Officer or alternative position as required by local regulation;
6.1.2.
a customer due diligence programme incorporating customer identification and verification based on information issued or obtained from independent and reliable sources and know your customer principles;
6.1.3.
conducting enhanced due diligence on customers assessed as higher risk;
6.1.4.
mplementing processes and systems to monitor customer transactions to identify suspicious activity;
6.1.5.
investigating and, where appropriate, reporting suspicious activity to applicable regulatory bodies;
6.1.6.
compulsory training of IZI Interactive Ltd employees and contractors in relation to financial crime risks;
6.1.7.
prohibiting business with customers with an unacceptable level of risk;
6.1.8.
continually monitoring levels of purchases and redemptions and evaluating these against anticipated account activity, the estimated net worth of the customer and the data and information retained on the customer's economic profile;
6.1.9.
investigating any significant deviations in what IZI Interactive Ltd understands of a customer's economic profile and their level of purchases;
6.1.10.
additional local requirements applicable to IZI Interactive Ltd from time to time.
Ver. 3.0.1 - 05 March 2025