AML Policy

HCTOPUP AML Policy

1. Introduction
This policy of HCTOPUP prohibits and actively pursues the prevention of money laundering and any activity that facilitates money laundering or the financing of terrorist and terrorist activities. HCTOPUP requires its managers, employees, and affiliates to adhere to the policy in preventing the use of the Company Services for money laundering purposes.

2. Legal Bases
HCTOPUP operates in jurisdictions with stringent Anti-Money Laundering (AML) regulations. We are committed to working with local financial authorities, and HCTOPUP is committed to complying with international standards and local laws and jurisdictions, strengthening and adapting our internal controls to combat illegal activities.

The HCTOPUP policy is implemented based on, but not limited to, the following provisions:
● FATF 40 Recommendations
● The US Bank Secrecy Act (BSA) and the US Anti-Money Laundering, Terrorist Financing and Foreign Sanctions Act (AML Act)
● UK Money Laundering Regulations (MLR) and Proceeds of Crime Act (PACE)
● EU Anti-Money Laundering Directive and Regulations
● CN Anti-Money Laundering and Countering the Financing of Terrorism Law

3. Transaction Monitoring and Evaluation
HCTOPUP will implement an effective transaction monitoring mechanism to identify and investigate transactions that may involve money laundering or other irregular activities through systematic and manual reviews. User risk assessments and transactions will also be conducted regularly;
We predict the average level of virtual items acquired by normal individual players in the game based on the length of the game's server opening time, and use this as a basis to determine whether the virtual items sold by the player are abnormal;
We constantly set and adjust daily transaction limits and withdrawal limits based on security requirements and actual transaction conditions;
If transactions occur frequently in your registered account or exceed a reasonable range, our team will evaluate and determine whether the transaction is suspicious;
If we determine that a transaction is suspicious based on our evaluation, we may take restrictive measures such as suspending or rejecting the transaction. If possible, we may cancel the transaction and report it to the competent authority without notifying you. We retain various types of records, including but not limited to customer identification documents, transaction logs, suspicious transaction reports, internal audits, and other records. These records are retained according to regulatory requirements for periods that may vary depending on the type of record.
Anti-money laundering regulations require us to monitor and track suspicious transactions and report to relevant law enforcement agencies. If we believe there is any connection with criminal activities or money laundering, we reserve the right to refuse transactions at any stage.

4. User suspicious activity
Where any suspicions arise that criminal conduct may have taken place involving a customer, or third party, we will consider whether there is a risk that money laundering has occurred or may occur.
Some examples of suspicious activities to be reported include:
1. A customer provides insufficient, false, or suspicious information or is reluctant to provide complete information.
2. Requests by a customer to pay in cash.
3. Payments to or from third parties that have no apparent or logical connection with the customer or transaction.
4. Payment to or from countries considered high risk for money laundering.
5. Payments from countries unrelated to the transaction or not logical for the customer.
6. Overpayments followed by directions to refund a payment, especially if requested to send the payment to a third party.
7. Any customer for whom we cannot determine the true beneficial owner.
8. Unexpected spikes in a customer‘s activities.
9. Purchase any Offer created by him/herself, or an agent of him/herself.
10. Register or make use of more than one HCTOPUP account.
11. Confirm delivery before its completion.
12. Return purchased products or services to the Seller under any circumstances except when appropriately arbitrated by HCTOPUP staff.

5. HCTOPUP Rights and Duties
Verify the Buyer and Buyer’s payments;
Hold the Buyer’s payments until HCTOPUP has determined the Order’s completion state;
HCTOPUP shall make an appropriate refund to Buyer for any product or service that HCTOPUP believes has not been delivered;
Protect the Seller from payment fraud;
Appropriately disburse payment to the Seller, deducting HCTOPUP fees, for any products or services that are deemed by HCTOPUP to have been properly delivered;
Reserve the right to prosecute the Buyer or Seller, to the fullest extent of the law, should there be any fraudulent activity.

If a transaction escalated to the HCTOPUP Final Resolution Committee.HCTOPUP should be entitled to:
Impartially arbitrate any disputes between the Buyer and Seller to the fullest extent possible;
Continue holding the Buyer’s payments until HCTOPUP determines the completion state of the Order;
Continue to protect the Seller from fraudulent payments;
Meticulously review the evidence of delivery provided by the seller and verify to the fullest extent possible that they have complied with the Secure Seller Delivery Agreement.
Verify to the fullest extent possible that the Buyer has abided by the Secure Buyer Delivery Agreement;
Review the trading history of the Buyer and Seller;
Rigorously verify the Buyer and Seller involved in the transaction, as well as a review of the Offer and Order;
Review any communications sent between the Buyer and Seller through the HCTOPUP Onsite Messaging System that are related to the Order;
Reserve the right to perform any additional assessment or investigatory step required for the final resolution of a dispute.

HCTOPUP takes a firm stand against identity theft and fraud. HCTOPUP takes a variety of orthodox and unorthodox measures to prevent, track, investigate, and log fraudulent activity.

As a policy, HCTOPUP will aggressively pursue, to the fullest extent of the law, the prosecution of any individuals or groups who engage in fraudulent activity on the Site，which includes fully supplying all relevant personal, transactional, and other identifiable information to the appropriate legal authorities, including, without limitation, international anti-money laundering organizations (FAFT), Internet Fraud Complaint Center（IFCC）, financial regulators in your region, and payment service providers of the HCTOPUP platform.

HCTOPUP will also report fraudulent activities to related ISPs (Internet Service Providers) for action under their Acceptable Use Policies.

In addition to potential criminal cases, HCTOPUP may file a separate civil case against an offender to recover any damages and costs (financial and otherwise) incurred.HCTOPUP does not take into consideration the scale of the fraud, the age of the fraudulent individual, or the absence of physical harm. HCTOPUP investigates, prosecutes, and litigates to the fullest extent possible, regardless of cost.

6. Policy Updates and Tips
We will periodically review and update the Anti-Money Laundering Policy. HCTOPUP will notify the user promptly of any changes to the policy and an updated version of the policy will post on our website.