Financial Crime Prevention Policy

Comprehensive framework for preventing, detecting, and reporting money laundering, terrorist financing, fraud, and other financial crimes on the POPS.GG platform.

Zero Tolerance Policy Statement

CASH.BH LTD (Company No. 14298863), operating POPS.GG, maintains a zero-tolerance approach to financial crime. We are committed to:

  • Preventing our platform from being used for money laundering or terrorist financing
  • Detecting and preventing fraud in all its forms
  • Complying with all applicable UK and international regulations
  • Reporting suspicious activity to relevant authorities without delay
  • Cooperating fully with law enforcement investigations

Financial Crime Prevention Framework

Multi-layered approach to preventing and detecting financial crimes

Risk-Based Approach

Comprehensive risk assessment methodology for all business relationships and transactions

  • Customer risk scoring based on business type, location, and transaction patterns
  • Enhanced due diligence for high-risk clients and jurisdictions
  • Ongoing risk assessment and periodic re-evaluation
  • Automated risk triggers for manual review
  • Senior management oversight for high-risk relationships

Transaction Monitoring

Real-time automated monitoring of all financial transactions across the platform

  • 24/7 automated transaction screening and analysis
  • Pattern recognition for unusual activity detection
  • Velocity checks and threshold monitoring
  • Cross-account transaction correlation
  • Machine learning models for anomaly detection

Sanctions & PEP Screening

Continuous screening against international sanctions lists and politically exposed persons databases

  • Real-time screening against OFAC, UN, EU, UK HMT sanctions lists
  • PEP database screening (World-Check, Dow Jones)
  • Adverse media monitoring and screening
  • Automatic alerts for sanctions list updates
  • Enhanced due diligence for PEP matches

Fraud Detection

Multi-layered fraud detection systems protecting against various fraud typologies

  • Identity verification and authentication controls
  • Device fingerprinting and behavioral biometrics
  • Transaction fraud scoring and rule-based detection
  • Account takeover prevention measures
  • Collaborative fraud intelligence sharing

Transaction Monitoring Rules

Automated rules and thresholds triggering manual review and investigation

Transaction Thresholds

  • •Single transaction exceeding £10,000 triggers manual review
  • •Daily aggregate transactions exceeding £25,000 require verification
  • •Unusual transaction patterns compared to historical baseline
  • •Rapid succession of transactions (velocity monitoring)
  • •Round-number transactions suggesting structuring

Behavioral Indicators

  • •Sudden changes in transaction volume or frequency
  • •Transactions inconsistent with stated business purpose
  • •Multiple failed transaction attempts
  • •Use of multiple payment methods or accounts
  • •Login from unusual locations or devices

High-Risk Indicators

  • •Transactions involving sanctioned countries or entities
  • •Matches against known fraud databases
  • •Use of anonymous or privacy-enhancing technologies
  • •Refusal to provide required documentation
  • •Involvement of shell companies or complex ownership structures

Regulatory Reporting Procedures

Mandatory reporting to UK authorities for suspicious activities

Suspicious Activity Reports (SARs)

Authority:

National Crime Agency (NCA)

Trigger:

Any activity suspected of money laundering or terrorist financing

Timeline:

As soon as reasonably practicable after suspicion arises

Reporting Process:

  1. 1.Internal escalation to Money Laundering Reporting Officer (MLRO)
  2. 2.MLRO reviews evidence and makes determination
  3. 3.SAR submitted to NCA via online portal if suspicion confirmed
  4. 4.Account activity may be suspended pending investigation
  5. 5.No disclosure to customer (tipping off prevention)
  6. 6.Records maintained for minimum 5 years

Terrorist Financing Reports

Authority:

National Crime Agency (NCA)

Trigger:

Reasonable grounds to suspect terrorist financing

Timeline:

Immediate reporting required

Reporting Process:

  1. 1.Immediate escalation to MLRO and senior management
  2. 2.Emergency SAR submission to NCA
  3. 3.Cooperation with law enforcement investigation
  4. 4.Account freezing as required by authorities
  5. 5.Enhanced monitoring of related accounts
  6. 6.Ongoing cooperation and updates to authorities

Large Cash Transactions (LCT)

Authority:

HM Revenue & Customs (HMRC)

Trigger:

Single cash transaction over £10,000 or equivalent

Timeline:

Within 15 days of transaction

Reporting Process:

  1. 1.Automatic system flagging of large cash transactions
  2. 2.Collection of customer identification and details
  3. 3.LCT report submitted to HMRC
  4. 4.Records maintained for minimum 5 years
  5. 5.Enhanced monitoring of related activity

Control Measures & Security

Comprehensive controls protecting against financial crimes

Know Your Customer (KYC)

  • Comprehensive identity verification for all clients
  • Beneficial ownership disclosure and verification
  • Business legitimacy and registration verification
  • Source of funds and wealth verification
  • Ongoing monitoring and periodic re-verification

Transaction Controls

  • Transaction limits based on risk assessment
  • Velocity controls and daily aggregate limits
  • Multi-factor authentication for high-value transactions
  • Cooling-off periods for unusual activity
  • Manual approval requirements for high-risk transactions

Access Controls

  • Role-based access control (RBAC) for staff
  • Multi-factor authentication for all accounts
  • IP whitelisting for administrative functions
  • Audit logging of all system access and changes
  • Regular access reviews and privilege management

Data Security

  • End-to-end encryption for sensitive data
  • Secure data storage with encryption at rest
  • Regular security audits and penetration testing
  • Data loss prevention (DLP) measures
  • Incident response and breach notification procedures

Governance Structure

Money Laundering Reporting Officer (MLRO)

  • Overall responsibility for AML/CFT compliance program
  • Review and submission of suspicious activity reports
  • Staff training and awareness programs
  • Liaison with law enforcement and regulatory authorities
  • Annual compliance reporting to board of directors

Compliance Team

  • Day-to-day monitoring of transactions and accounts
  • Customer due diligence and enhanced due diligence
  • Investigation of suspicious activity alerts
  • Maintenance of policies and procedures
  • Regulatory reporting and record-keeping

Senior Management

  • Oversight of financial crime prevention program
  • Approval of high-risk customer relationships
  • Resource allocation for compliance function
  • Review of compliance performance metrics
  • Board reporting on financial crime risks

Staff Training Program

All POPS.GG employees receive comprehensive training on financial crime prevention, including:

  • Mandatory AML/CFT training for all employees at onboarding
  • Annual refresher training with updated regulatory requirements
  • Role-specific training for compliance and operational staff
  • Regular awareness bulletins on emerging threats and typologies
  • Testing and certification to ensure knowledge retention
  • Senior management briefings on regulatory developments

Report Suspicious Activity

If you observe or suspect financial crime on our platform, please report it immediately

MLRO Email: mlro@pops.gg

Compliance Email: compliance@pops.gg

All reports are treated confidentially and protected by law

Contact Compliance Team