Effective date: May 2026
IQ Cleaning LTD operates a commercial platform for an online game and eligible digital in-game items, including game cards and similar virtual items used in gameplay. It does not offer customers payment accounts, money-remittance services, electronic money, acquiring services or a general facility for transferring money between users.
Amounts paid to sellers represent consideration due to completed platform sales. Where a seller is paid through a card-based or other approved payout channel, the payment is arranged through an authorised acquiring bank or payment partner. IQ Cleaning's role is to determine the seller's commercial entitlement and submit the payout instruction; the regulated payment leg is performed by the authorised partner.
This Policy is therefore a voluntary AML/CFT control framework for IQ Cleaning's platform and seller-payout activity. It reflects applicable UK legal requirements, the Company's own risk standards, and contractual expectations imposed by acquiring banks, payment partners and relevant Card Schemes. Nothing in this Policy is intended to describe IQ Cleaning as a bank, payment institution, electronic-money institution or statutory AML-regulated "relevant person".
Overall responsibility for this document rests with the Director including the administration and maintenance of the policy. This document is issued, approved and became effective in May 2026. The policy will be reviewed at least once every 12 months. An interim review may also be initiated whenever significant changes occur in legislation or regulation, the organization's products or services, its business partners, or its overall risk exposure.
The purpose of this Policy is to protect IQ Cleaning, its customers, its payment partners and the integrity of its platform from misuse involving money laundering, terrorist financing, sanctions evasion, fraud, account compromise, dealing in criminal property or other illicit activity. The Policy is designed around the risks created by remote trading in digital in-game items and the subsequent payment of legitimate sale proceeds to sellers.
The Policy applies to directors, employees, contractors and outsourced personnel whose work may affect customer onboarding, account security, transaction review, seller payouts, sanctions screening, fraud controls, finance, customer support or regulatory/partner communications. Controls are applied on a risk-sensitive basis and may be strengthened where the facts of a customer, transaction, geography or payout destination warrant additional review.
IQ Cleaning adopts these controls even where a specific obligation under the Money Laundering Regulations 2017 does not directly apply to the Company. Voluntary adoption of AML/CFT measures is intended to support lawful and responsible platform operation and must not be interpreted as an admission that IQ Cleaning is carrying on regulated payment services.
IQ Cleaning provides a platform through which users may play an online game, purchase and sell eligible digital in-game items. IQ Cleaning does not sell, transfer, or take custody of a user's game account merely because that account is used to evidence ownership or complete delivery of an item.
A buyer pays for an identified digital item. Once the relevant transaction and delivery conditions are satisfied, IQ Cleaning records the amount contractually due to the seller, subject to applicable fees, refunds, reversals, reserves or other adjustments under the platform terms. Any seller-facing balance or entitlement record is an internal record of the Company's commercial liability; it is not intended to function as a customer deposit, payment account, transferable stored-value balance or e-money product.
The platform is not designed to allow one user to instruct IQ Cleaning to send unrelated funds to another user. Users may not use the platform as a substitute for a money-transfer service, fund an account solely for later withdrawal, or transfer internal balances among themselves. A seller payout is released only for verified proceeds arising from completed platform activity.
IQ Cleaning's legal framework takes account of the UK laws that may be relevant to the Company's activities, including the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), the Sanctions and Anti-Money Laundering Act 2018 and regulations made under it, the Fraud Act 2006, and applicable UK data-protection legislation.
The Company is not a "relevant person" under the Money Laundering Regulations solely because it operates a digital-goods platform or arranges payment of amounts owed to sellers through an authorised payment partner. Nevertheless, IQ Cleaning shall not knowingly assist criminal conduct, handle criminal property, facilitate terrorist financing, or make funds or economic resources available in breach of applicable sanctions.
IQ Cleaning also recognises that the payment-services perimeter depends on the substance of the funds flow and the functions performed. The Company's model must therefore continue to ensure that regulated payment execution is performed by an appropriately authorised bank or payment partner and that IQ Cleaning does not evolve into a provider of stand-alone payment or remittance services without prior regulatory analysis.
Where Card Scheme payout or disbursement channels are used, IQ Cleaning shall operate within the use case, transaction type, geographic scope, data requirements, limits and controls approved by its acquiring bank or payment partner. Contractual partner requirements apply in addition to the internal standards in this Policy.
The Director holds ultimate responsibility for this Policy. The Director may in the future assign day-to-day administration to an internal AML & Sanctions Compliance Officer ("AMLCO"). The AMLCO is an internal control function and is not described as a statutory MLRO unless such an appointment becomes legally required.
The Director shall:
The Director or AMLCO or other designated control owner shall maintain procedures, oversee screening and risk-based reviews, document material decisions, coordinate partner notifications where required, and keep relevant staff informed of control changes. Employees and contractors must follow approved procedures and may not bypass payout holds, screening results, or approval thresholds without documented authority.
IQ Cleaning shall maintain a documented assessment of the financial-crime risks arising from its customers, digital-item platform activity and seller payout process. The assessment should consider both the likelihood of misuse and the effectiveness of existing controls, so that enhanced measures are directed to the areas of greatest residual risk.
| Risk area | Examples of exposure | Typical mitigating measures |
|---|---|---|
| Customer and account | Unverified identity; linked accounts; account takeover; inconsistent personal data; prior fraud history. | Identity checks; device/account authentication; linked-account analysis; manual review. |
| Platform behaviour | Rapid buy/resell activity; circular trading; abnormal pricing; use of compromised game/platform accounts. | Transaction analytics; item-delivery evidence; price and behavioural review; restrictions. |
| Seller payout | Unusual value or velocity; frequent destination changes; shared payout instruments; failed/retried transactions. | Payout limits; destination controls; cooling-off periods; re-authentication; case review. |
| Geography | Sanctioned or high-risk locations; unexplained cross-border combinations; IP/residence/payout mismatches. | Geographic restrictions; sanctions screening; enhanced verification; partner controls. |
| Third parties | Failure or weakness at acquiring bank, processor, verification vendor or game/platform integration. | Due diligence; contractual controls; service monitoring; contingency planning. |
| Regulatory / programme | Change in law, partner approval, Card Scheme use case or product functionality. | Periodic legal review; change-management; documented partner approval. |
Users or activity may be classified using a documented risk scale such as Standard, Heightened and Unacceptable. The selected label is less important than consistently applying stronger controls to higher-risk cases. Activity that would breach law, sanctions, payment-partner requirements, Card Scheme restrictions or the operating boundaries in Section 2 must not proceed.
IQ Cleaning shall collect and maintain sufficient information to associate platform activity and seller payouts with an identifiable customer account. The depth of verification shall reflect the customer's activity, payout value, fraud exposure, geographic risk, and any stricter requirement imposed by the acquiring bank or payment partner.
Before a seller becomes eligible to receive funds, the Company should ordinarily have the seller's name, date of birth, contact details, country of residence, platform account identifier and relevant payout-destination information. Verification may use government-issued identity documents, reliable electronic verification, liveness or biometric tools, where lawful, device/account authentication, payment-instrument verification or other independent evidence proportionate to the risk.
A seller payout may be released only where:
Higher-risk cases may require enhanced due diligence. Depending on the circumstances, IQ Cleaning may request additional identity evidence, confirmation of payout-instrument ownership, an explanation and supporting evidence for unusual trading activity, information on the source of funds or source of wealth where relevant, management approval, reduced limits, delayed release, or additional monitoring.
IQ Cleaning shall apply sanctions screening in a manner proportionate to the information available and the relationship risk. At a minimum, customers and seller payouts shall be screened as required against applicable United Kingdom sanctions data and any additional lists mandated by the acquiring bank, payment partner or approved Card Scheme programme.
Potential sanctions matches must be placed on hold and reviewed using available identifiers such as full name, aliases, date of birth, nationality, residence and other relevant information. A payout must not be released while a material match remains unresolved. Confirmed concerns shall be handled in accordance with applicable freezing, rejection, reporting and escalation requirements.
PEP and adverse-information checks may be performed universally or on a risk-triggered basis. A PEP relationship is not automatically prohibited. Instead, the Company shall consider the person's role, geography, transaction behaviour, source/purpose of value and any partner requirements, and apply enhanced review or senior approval where appropriate. Credible adverse information concerning fraud, cybercrime, stolen accounts, sanctions evasion, money laundering, terrorist financing or serious criminal conduct should be assessed before a decision is made.
IQ Cleaning's preventive controls are intended to ensure that payout remains connected to legitimate platform activity and cannot readily be used as an unrelated cash-out mechanism. Operational procedures may be automated, manual, or a combination of both, depending on transaction volume and risk.
| Safeguard type | Outcome |
|---|---|
| Sale-to-payout linkage | Every payout can be traced to completed digital-item sales and the seller's resulting net entitlement. |
| Account authentication | The payout event is linked to an authenticated account, with step-up checks after material account changes or where risk is elevated. |
| Destination integrity | Payouts are directed only to a permitted destination associated with the seller; unexplained third-party destinations are not accepted. |
| Value and velocity controls | Per-transaction and cumulative thresholds are maintained in line with risk appetite and any stricter partner or Card Scheme limits. |
| Change-event controls | Recent password recovery, contact-detail change, device change, or a new payout instrument may trigger a hold, re-authentication, or manual review. |
| Transaction traceability | The platform, payout, and processor identifiers are retained so transactions can be reconciled and investigated. |
| Cross-border restrictions | Country combinations are checked against sanctions, partner approval and programme restrictions before release. |
| Exception governance | Manual credits, overrides, unusual retries, reversals or special-case payouts require documented authorised review. |
Where cardholder data is processed, IQ Cleaning shall comply with applicable PCI DSS and payment-partner security requirements and minimise the amount of sensitive payment data stored by the Company.
IQ Cleaning shall monitor customer activity for patterns inconsistent with normal platform use or that indicate fraud, laundering, sanctions evasion, or account compromise. Monitoring may combine system rules, behavioural analytics, and manual investigation.
Examples of matters warranting review include unusually rapid trading followed by cash-out, linked accounts repeatedly trading with one another, extreme price deviations, sudden increases in payout value, repeated use of shared payout instruments, structuring below limits, account recovery immediately before payout, significant country inconsistencies, repeated failed verification or screening, and patterns associated with chargebacks or stolen payment credentials.
An internal case record should document the facts reviewed, relevant evidence, decision, restrictions applied, and any follow-up action. IQ Cleaning may delay, reject, or cancel a payout, or restrict an account where permitted by law and contract, while a concern is being assessed.
Material concerns must be escalated to the Director. The Director shall determine, with legal advice where appropriate, whether a disclosure or notification is required or appropriate under POCA, the Terrorism Act, sanctions legislation, another applicable law, a lawful authority request or the Company's partner agreements. This may include communication with the National Crime Agency, the Office of Financial Sanctions Implementation, an acquiring bank, a payment partner or another competent body where applicable.
Customer-facing explanations for holds or restrictions must not reveal confidential screening methods, sensitive investigative information or external reporting decisions where such disclosure is prohibited or could prejudice a review.
The Company shall keep records sufficient to reconstruct relevant customer verification, platform activity, payout entitlement, screening, monitoring alerts, review decisions, exceptions and communications with payment partners or authorities. Records must be retrievable and protected against unauthorised alteration or access.
IQ Cleaning may retain relevant financial-crime and payout-control records for five years following the relevant transaction or the end of the customer relationship, unless a different period is required by law, litigation hold, partner contract or the Company's approved retention schedule. This internal period does not imply that every statutory retention requirement applicable to MLR-regulated firms automatically applies to IQ Cleaning.
Personal data shall be handled in accordance with the UK GDPR, the Data Protection Act 2018 and the Company's privacy and security procedures. Financial crime controls should follow data-minimisation and access-control principles and should not collect more sensitive information than is reasonably required for the stated purpose.
IQ Cleaning shall conduct proportionate due diligence on material third parties supporting payouts, identity verification, screening, processing, fraud prevention or platform integrations. The Company should understand the service provided, the provider's role in the control chain, relevant security and regulatory status, contractual obligations and escalation arrangements.
Personnel whose roles affect customer verification, payouts, fraud controls, support, finance or compliance shall receive appropriate training when joining and periodically thereafter. Training should explain the Company's platform model, the distinction between commercial seller payouts and general money transfer, sanctions escalation, suspicious platform patterns, account-takeover risks, handling of sensitive data and the prohibition on unauthorised control overrides.
IQ Cleaning prohibits bribery, corruption, kickbacks, collusion and manipulation of customer or payout records. No employee should be able, without appropriate authority, to create unsupported seller value and release it for payment. Material manual credits, refunds, balance adjustments or payout overrides should therefore be subject to documented approval and, where practicable, segregation of duties or second-person review.
The Company shall periodically test the effective operation of key controls, including identity verification, sanctions screening, transaction monitoring, payout restrictions, exception approvals and record keeping. The Company must document material weaknesses, assign an owner, and track remediation. Independent review may be commissioned where required by a payment partner or where the risk profile warrants it.
This Policy shall be reviewed at least annually and sooner where there is a material change to UK law or guidance, the Company's product design, supported jurisdictions, acquiring-bank or payment-partner requirements, Card Scheme programme conditions, fraud experience or financial-crime risk profile.
A business-change review is mandatory before introducing functionality that could alter IQ Cleaning's regulatory classification or the character of seller payouts. Examples include customer-to-customer transfer capability, transferable balances, custody of customer funds, funding for later withdrawal, materially different platform settlement flows, or changes that cause IQ Cleaning to receive or transmit money as an intermediary.
Approved changes must be reflected in relevant procedures, system rules, staff training and partner documentation before the new activity is launched.
| Indicator | Illustrative indicators requiring consideration |
|---|---|
| Identity / account security | Failed re-authentication; inconsistent identity data; multiple accounts sharing key identity/device elements; unusual recovery requests; new device immediately followed by payout. |
| Platform behaviour | Circular or linked-account trading; rapid buy/resell activity without clear economic rationale; material departure from normal item prices; abnormal concentration in selected items. |
| Fraud exposure | Purchases associated with compromised payment credentials; high chargeback ratios; known stolen or compromised game/platform accounts; repeated payment failures followed by successful cash-out. |
| Payout destination | Multiple unrelated users using the same destination; one user frequently changing destinations; mismatch between customer profile and payout country; unexplained third-party instrument. |
| Velocity / structuring | Transactions repeatedly fell just below limits; sudden increase in payout frequency; and many small sales followed by immediate aggregate payout. |
| Geography / sanctions | Connection to restricted jurisdictions or designated persons; unexplained mismatch among residence, IP/device data, payment source, and payout destination. |
| Customer behaviour | Inconsistent explanations; pressure on staff to bypass controls; attempts to obtain unsupported credits; unwillingness to provide reasonable verification information. |
| Fraud or Adverse media information | Fraud notices, reversals, repeated complaints, unauthorised-account claims or adverse information from processors, banks, platforms or other credible sources. |
A payout should not be released until the following conditions have been satisfied or an authorised exception has been documented:
