AML & Identity Verification Policy

Atomance LTD operates ADYTUS with controls designed to prevent money laundering, terrorist financing, fraud, and sanctions evasion. This page summarizes the program for users; it is part of the Terms of Service. The full internal program — risk assessment, procedures, training, and independent review — is maintained separately under a designated compliance officer. [PROGRAM OWNER / MLRO — TBD BY COUNSEL]

1. Why a skill-contest platform runs AML controls

Real money enters ADYTUS in exactly one way (flat contest entry fees) and leaves in exactly one way (fixed, rank-based prizes). That narrow design already limits abuse — there are no user-to-user transfers, no deposits held on account, no withdrawal of anything except a verified prize, and in-contest credit (CV) has no cash value and cannot be moved between users. The controls below protect the two points where money does move.

2. The program at a glance

• a designated compliance officer accountable for the program;
• written, risk-based procedures reviewed at least annually;
• identity verification before any prize payout;
• sanctions and watch-list screening, repeated periodically;
• transaction monitoring tuned to our two money legs;
• record-keeping and reporting as required by law; and
• staff training and independent testing. [TRAINING / AUDIT CADENCE — TBD]

3. Identity verification (KYC)

Consistent with the USA PATRIOT Act and applicable law, we obtain, verify, and record information that identifies every user who receives a prize — and earlier where the law or our risk assessment requires. Verification is performed with a specialist provider (Sumsub) and typically covers:

• full legal name, date of birth, and residential address;
• a government identifier where required (for example, SSN/TIN for US tax reporting);
• a government-issued photo ID, checked for authenticity; and
• a liveness check that the person presenting the ID is its holder.

If verification cannot be completed, the prize is held until it is — and if it cannot be completed at all, the prize is handled as the Official Contest Rules and applicable law require.

4. Sanctions, watch lists, and prohibited persons

We screen users against applicable sanctions lists (including OFAC lists for US purposes) and do not provide real-money contests to sanctioned persons, to persons located in comprehensively sanctioned territories, or to anyone prohibited by law. Screening runs at verification and is repeated periodically, because lists change. A true match ends the relationship and is reported where the law requires. Heightened review applies where the law requires it, including for politically exposed persons. [PEP POLICY DETAIL — TBD]

5. Monitoring — what looks suspicious here

Because the money surface is narrow, monitoring focuses on the patterns that could abuse it, for example:

• attempts to create multiple or synthetic identities;
• entry-fee payments from cards or accounts that do not match the verified identity;
• structured or unusually rapid sequences of entries inconsistent with play;
• collusion patterns designed to steer prizes to a particular account;
• chargebacks and payment disputes used as a laundering or fraud tool;
• prize-payout requests routed to instruments that fail verification.

We may ask you for more information — including source of funds — before accepting an entry or releasing a payout, and we may decline either where the risk cannot be resolved.

6. Holds, declines, and account exits

We may pause entries, hold a payout, restrict an account, or end the relationship while a verification, investigation, or legal process is in progress. Where the law prohibits telling you why (for example, around certain reports), we will not be able to explain — this is a legal constraint, not a discourtesy. Verified prize amounts that survive investigation remain payable.

7. One identity per person

Each person may hold exactly one account. Duplicate, synthetic, or borrowed identities — and entering a single contest more than once through any account — result in disqualification, forfeiture of related prizes, and closure of the accounts involved. This rule also protects the fairness every other entrant paid for.

8. Reporting and cooperation with authorities

Where required, we file reports with, and respond to lawful requests from, competent authorities — including tax reporting on prizes and suspicious-activity reporting — and we may do so without notice to you where notice is prohibited. You agree to cooperate with reasonable verification requests. [SAR/CTR OBLIGATIONS AS APPLICABLE TO OUR LICENSING — TBD BY COUNSEL]

9. Records

We retain verification and transaction records for the period required by applicable law, including after account closure [RETENTION PERIOD — TBD BY COUNSEL]. Records are held under the safeguards described in the Privacy Policy and Security pages; verification documents themselves are held by our KYC provider, not on our servers.

10. What this means for you, practically

• Free play needs an account and the 18+ check — not document verification.
• You can pay an entry fee before completing full verification; you cannot receive a prize until verification is complete.
• Use your own name, your own payment method, and one account — the fastest path to a smooth payout.
• If we ask for documents, responding promptly is the quickest way to release a hold.

11. Contact

Verification help: support@adytus.com · Compliance and legal: legal@adytus.com