Anti-Money Laundering (AML) and KYC Policy

1. Introduction

Nameless Ltd ("CSBattle," "we," "us," or "our") is fully committed to upholding a secure, lawful, and compliant environment within our gaming and entertainment platform, CSBattle. To this end, we have instituted a rigorous Anti-Money Laundering ("AML") Policy designed to preclude the use of our platform for unlawful purposes, including but not limited to money laundering and the financing of terrorism. This policy pertains to all operations conducted on our website, www.csbattle.com, which is owned and operated by Nameless Ltd.

2. Know Your Customer (KYC) Procedures

In compliance with applicable regulatory frameworks, CSBattle implements stringent Know Your Customer ("KYC") procedures to ensure the verification of user identities and the mitigation of money laundering and terrorist financing risks. Our KYC protocols are aligned with prevailing regulatory requirements and are subject to continuous review and enhancement to maintain their efficacy.

To facilitate adherence to AML regulations, CSBattle collaborates with Sumsub, a preeminent provider of KYC and AML solutions. Sumsub is entrusted with the execution of advanced KYC checks, particularly in instances involving the withdrawal of funds from FIAT deposits to cryptocurrency. In such cases, users are mandated to furnish the following documentation:

Full legal name
Date of birth
Residential address
A government-issued identification document (e.g., passport, national ID card, or driver's license)
Proof of residential address (e.g., utility bill, bank statement, or equivalent documentation)
Sumsub employs sophisticated verification methodologies, including but not limited to facial recognition technology and biometric data analysis, to authenticate the provided documents.

3. AML Controls

CSBattle has instituted a comprehensive suite of AML controls, designed to thwart money laundering and other unlawful activities on our platform. These controls are calibrated to meet the standards set forth by relevant regulatory authorities and are regularly reviewed and updated to ensure continued compliance.

• 3.1 Transaction Monitoring: CSBattle conducts continuous monitoring of all transactions occurring on its platform, with a particular focus on identifying suspicious activity, such as large transactions, anomalous patterns, and transactions originating from or directed to jurisdictions designated as high-risk. Our monitoring framework is underpinned by advanced machine learning algorithms and rule-based detection systems.

• 3.2 Risk Assessment: CSBattle undertakes periodic risk assessments to identify and evaluate potential AML risks associated with its operations. Users are classified based on their respective risk profiles, with appropriate AML controls applied accordingly. This assessment considers factors such as the user’s geographic location, transaction history, and engagement in gaming activities on our platform.

• 3.3 Employee Training: CSBattle ensures that its personnel are equipped with the necessary knowledge and skills to identify and mitigate AML risks. To this end, we provide regular training sessions on AML regulations, risk assessment methodologies, and the identification of suspicious activity.

• 3.4 Customer Due Diligence (CDD): CSBattle performs customer due diligence on all users as part of its verification and risk assessment processes. Enhanced due diligence is conducted for high-risk users, including politically exposed persons (PEPs) and individuals from high-risk jurisdictions. Our CDD procedures are designed to comply with relevant legal requirements and are regularly updated to ensure ongoing effectiveness.

• 3.5 Enhanced Transaction Monitoring: In addition to routine transaction monitoring, CSBattle employs enhanced monitoring systems to detect suspicious activity, particularly transactions involving high-risk jurisdictions, high-value transfers, and transactions lacking a clear economic or lawful purpose. These systems are designed to generate alerts, prompting further investigation as necessary.

• 3.6 Record Keeping: CSBattle maintains comprehensive records of all transactions conducted on its platform, including user identification information, transaction histories, and risk assessments. These records are retained for a minimum duration of five years, in compliance with statutory requirements.

4. External Collaboration

To reinforce our AML measures, CSBattle engages with external entities, including but not limited to the following:

• 4.1 Sumsub: Our designated partner for conducting KYC checks on withdrawals involving the conversion of cryptocurrency to FIAT currency.

• 4.2 Law Enforcement and Regulatory Authorities: CSBattle cooperates fully with law enforcement and regulatory bodies in the investigation of suspected money laundering or terrorist financing activities.

• 4.3 AML Consultants: CSBattle retains the services of AML consultants to review, assess, and provide expert guidance on the optimization of our AML controls and procedures.

5. Conclusion

Nameless Ltd, through its platform CSBattle, remains steadfast in its commitment to maintaining a secure and compliant environment. We recognize the critical importance of preventing money laundering and terrorist financing and have implemented a comprehensive AML framework to address these risks effectively. Our AML controls and procedures are subject to regular review and enhancement to ensure ongoing compliance with applicable legal and regulatory requirements. Should you have any inquiries or concerns regarding our AML policy, please contact us at contact@csbattle.com.

Updated on: 25/06/2025