AML/KYC Policy

1. Introduction

This Anti-Money Laundering and Know Your Customer Policy (the “Policy”) explains the measures used by FCPacks to verify users, protect the FCPacks platform from financial crime, and comply with applicable legal and regulatory obligations.

FCPacks is operated by TopStreaks LTD, London, United Kingdom (“FCPacks”, “we”, “us” or “our”).

This Policy should be read together with our Terms of Service and Privacy Policy. It does not mean that every user or transaction will be subject to the same checks. We apply proportionate, risk-based controls and may change those controls as risks, products, payment methods, or legal requirements change.

2. Our Approach

FCPacks takes reasonable measures designed to prevent the platform, FC Credits, packs, rewards, marketplace features, payment methods, and delivery services from being used for money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful activity.

These measures may include:

• Identity and age verification.
• Address and payment-method checks.
• Transaction and account monitoring.
• Sanctions, politically exposed person, and adverse-media screening where appropriate.
• Enhanced due diligence for higher-risk activity.
• Restrictions, delays, or refusals relating to deposits, pack openings, redemptions, reward claims, deliveries, or other account functions.
• Reporting or disclosure to competent authorities where required or permitted by law.

3. Information We May Request

We may ask a user to provide information or documents including:

• Full legal name.
• Date of birth.
• Residential address and country of residence.
• Email address and telephone number.
• A valid government-issued identity document.
• A photograph, selfie, liveness check, or other evidence that the document belongs to the user.
• Proof of residential address.
• Information concerning the source of funds or source of wealth.
• Evidence of ownership of a payment method, bank account, or digital wallet.
• Information about a transaction, reward claim, delivery address, or the intended use of the account.

4. When Verification May Be Required

Verification may be required at registration or at any later time, including before or after:

• Purchasing or receiving FC Credits.
• Using particular payment methods.
• Completing high-value, unusual, or repeated transactions.
• Redeeming or claiming a reward.
• Requesting delivery of a physical reward.
• Changing important account, identity, or payment information.
• Accessing certain products, features, promotions, or jurisdictions.
• An account or transaction triggering a legal, security, fraud, or risk review.

5. User Responsibilities

Users must:

• Provide accurate, complete, current, and truthful information.
• Use only an account registered in their own name, unless FCPacks expressly permits otherwise.
• Use payment methods they are legally authorised to use.
• Respond promptly to reasonable verification requests.
• Keep account and contact information up to date.
• Not conceal their identity, location, ownership of funds, or the purpose of a transaction.
• Not use multiple accounts, third parties, intermediaries, or technical measures to avoid checks, limits, or restrictions.
• Notify FCPacks promptly if they suspect unauthorised or unlawful account activity.

6. Prohibited Activity

FCPacks must not be used to:

• Launder or disguise the proceeds of crime.
• Finance terrorism or other prohibited activity.
• Evade sanctions, legal restrictions, verification, or transaction limits.
• Commit fraud, payment abuse, chargeback abuse, identity theft, or promotion abuse.
• Conduct transactions for or on behalf of an undisclosed third party.
• Use FC Credits, rewards, or marketplace functions as a substitute for prohibited money transmission or cash conversion.
• Exploit errors, bugs, automated systems, or unintended platform functionality.

7. Monitoring and Reviews

We may review account and transaction activity on an ongoing or event-driven basis. Reviews may consider, among other factors:

• Transaction size, frequency, pattern, and payment method.
• Differences between account, payment, device, location, and delivery information.
• Multiple or linked accounts.
• Chargebacks, payment failures, or suspected stolen payment instruments.
• Attempts to avoid limits or verification.
• High-risk jurisdictions, sanctions exposure, or other financial-crime indicators.

8. Enhanced Due Diligence

Where a user, transaction, payment method, jurisdiction, or pattern of activity presents a higher risk, we may carry out enhanced checks. These may include requesting further identity evidence, source-of-funds or source-of-wealth information, supporting transaction records, or an explanation of account activity.

If we cannot complete the checks to our reasonable satisfaction, we may refuse, cancel, restrict, or terminate the relevant transaction, reward claim, delivery, feature, or account, subject to applicable law and the Terms of Service.

9. Sanctions and Restricted Jurisdictions

FCPacks may restrict or refuse access where a user, payment method, transaction, delivery destination, or other relevant party is subject to applicable sanctions or is located in a jurisdiction we do not support.

Users must not use virtual private networks, false information, intermediaries, or other methods to conceal their true location or evade jurisdictional restrictions.

10. Suspicious Activity and Disclosures

Where required or permitted by law, FCPacks may preserve records, reject or delay activity, and disclose information to payment providers, identity-verification providers, regulators, law-enforcement agencies, courts, or other competent authorities.

We may be legally prohibited from telling a user that a report, investigation, or disclosure has been made. Nothing in this Policy requires us to disclose confidential risk controls, monitoring rules, legal requests, or the existence or content of a suspicious-activity report.

11. Records and Data Protection

We retain verification, transaction, and compliance records for as long as reasonably necessary to provide the services, prevent fraud, resolve disputes, comply with legal obligations, and protect our legitimate interests.

We may retain certain records after an account is closed where required or permitted by law. For more information about how we collect, use, share, retain, and protect personal information, please see our Privacy Policy.

12. Account Restrictions and Termination

If a user does not complete requested checks, or if FCPacks reasonably suspects unlawful, fraudulent, abusive, or prohibited activity, we may take one or more of the following steps:

• Request additional information.
• Reject or reverse a transaction where possible and lawful.
• Delay or refuse a reward claim or shipment.
• Limit deposits, purchases, redemptions, or other features.
• Suspend or terminate the account.
• Withhold, remove, or cancel FC Credits or rewards where permitted under the Terms of Service and applicable law.
• Make any legally required report or disclosure.

13. Changes to This Policy

We may update this Policy periodically to reflect changes to our services, risks, controls, or legal obligations. The updated version will be published on the platform with a revised “Last Updated” date.

14. Contact Information

TopStreaks LTD

London, United Kingdom

Email: support@fcpacks.com

Questions about verification or this Policy may be sent to support@fcpacks.com. For security and privacy reasons, do not send identity documents by ordinary email unless FCPacks specifically instructs you to do so through an approved process.