Know Your Customer & Anti Money Laundering

1. Purpose

Moreton Media Ltd is a UK-based online prize competition business. The company offers a wide variety of different prizes. The company is headquartered in Cambridgeshire at PE29 9PY. Customers purchase tickets and complete a skill-based element in order to be eligible for a final drawing. Drawings are powered via Google Random Number Generator software and shared on livestream to ensure compliance and transparency. The company also ensures that all entrants are over the age of 18 prior to entry.

Legal Framework

In order to comply with gaming and random drawing laws in all targeted countries, the Company adheres to a stringent set of guidelines. The procedures and policies implemented by the Company for this purpose are set out below:

Due diligence procedures that include identification of customers.

Procedures that relate to record keeping of clients’ identity and their transactions, including payment method, contact information, skill-based element results and total individual sales.

Procedures that relate to random drawing of winners.

Appropriate procedures of internal control and risk management, with the purpose of preventing customer concerns relating to transparency.

Procedures that track individual purchases and relevant ticket drawing numbers.

Procedures that inform employees and contractors of the aforementioned procedures.

2. Policy

Procedures for frequent training of the employees and contractors in the recognition and handling of transactions and marketing.

The Company adopts procedures and processes that ensure compliance with all pertinent laws and regulations.

Customer identification and due diligence procedures:

Obtain confirmation of age before accepting payment from all players.

The aforementioned process is repeated for each transaction.

Continued monitoring of marketing language is a key focus of all senior management.

Each winner-drawing is powered by Google Random Number Generator software and is broadcast live via the company’s various social media channels.

3. Customer Purchase Procedures

3.1. Before allowing new customers to purchase tickets with the Company, the following KYC documents should be obtained on order to verify the Customer’s identity:

Copy of valid identification: passport; drivers license; etc.

Required documents for proof of address upon request: utility bill, bank statement.

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