Last updated: February 2026
This Anti-Money Laundering Policy is issued by REDDY STUDIOS LTD, registered at 1 Ariel Way, London, United Kingdom, W12 7SL (Company number: 16805476). This policy applies to all operations of the Stake Social Platform.
REDDY STUDIOS LTD ("the Company", "we", "us", or "our"), registered at 1 Ariel Way, London, United Kingdom, W12 7SL (Company number: 16805476), operates Stake Social Platform as a social gaming platform using virtual currency only.
We are committed to the highest standards of Anti-Money Laundering (AML) compliance and the prevention of financial crime. While our platform operates exclusively with virtual, non-redeemable currency and does not facilitate real-money gambling, we recognise our broader responsibilities as a technology company and uphold robust AML standards to prevent misuse of our platform for any illicit purposes.
This policy demonstrates our commitment to operating with integrity, transparency, and full compliance with applicable laws and regulations in the United Kingdom and internationally.
REDDY STUDIOS LTD maintains a zero-tolerance policy towards money laundering, terrorist financing, and all forms of financial crime. Our AML Policy is designed to:
All employees, contractors, agents, and third-party service providers are required to comply with this policy. Failure to adhere to these requirements may result in disciplinary action, termination of contract, and/or referral to the appropriate authorities.
We implement comprehensive KYC procedures to verify the identity of our users and understand the nature of their activity on our platform. Our KYC framework includes:
Users may be required to provide government-issued photo identification such as a passport, national identity card, or driving licence. We verify that the document is genuine, current, and belongs to the individual presenting it.
Proof of address documents (utility bills, bank statements, official correspondence) dated within the last three months may be requested to confirm a user's residential address.
All users must be 18 years of age or older to access our platform. Age verification is conducted during the registration process and may be supplemented by document-based verification where risk indicators are present.
In cases where enhanced scrutiny is warranted, users may be asked to provide documentation evidencing the legitimate source of funds used to purchase virtual currency on our platform.
KYC is not a one-time process. We continuously monitor user behaviour and may request updated documentation when circumstances change or risk levels escalate.
Standard Customer Due Diligence (CDD) is applied to all users upon registration and at appropriate intervals thereafter. Our CDD measures include:
We apply a risk-based approach to CDD, meaning the extent of measures taken is proportionate to the assessed risk. Customers are categorised as low, medium, or high risk based on factors including:
Low-risk customers receive standard due diligence. Medium and high-risk customers are subject to enhanced scrutiny as described in Section 5.
Enhanced Due Diligence (EDD) is applied in circumstances where the risk of money laundering or terrorist financing is assessed as higher than normal. EDD situations include, but are not limited to:
Individuals who hold or have held prominent public functions, as well as their family members and close associates, are subject to EDD. We obtain senior management approval before establishing or continuing a relationship with a PEP, and apply enhanced ongoing monitoring.
Customers with connections to countries identified by the Financial Action Task Force (FATF) as high-risk or subject to increased monitoring are subject to EDD measures, including independent source verification and senior management sign-off.
Where transactions or behavioural patterns are complex, unusually large, or have no apparent lawful purpose, EDD is triggered. This includes obtaining additional information on the purpose of the activity and the source of funds.
Any potential match against sanctions lists, watchlists, or significant adverse media coverage triggers an immediate EDD review and may result in account suspension pending investigation.
• Enhanced identity verification with certified documents • Detailed source of wealth and source of funds documentation • More frequent monitoring intervals • Requirement for senior management approval to continue the relationship
We operate a robust transaction monitoring system to detect patterns and behaviours that may indicate money laundering, fraud, or other financial crime. Our monitoring programme covers:
Our systems automatically flag transactions and activity that meet or exceed defined thresholds or exhibit suspicious patterns. Automated rules are regularly reviewed and updated to reflect the evolving risk landscape.
We analyse user behaviour over time to establish baseline patterns. Deviations from established patterns — such as sudden increases in purchase volume, unusual geographic access, or atypical usage patterns — trigger alerts for further review.
• Rapid purchase and reversal of virtual currency transactions • Structuring activity designed to stay below monitoring thresholds • Use of multiple accounts or payment methods by a single individual • Geographic inconsistencies between registration details and access locations • Rapid escalation of activity shortly after account creation • Activity inconsistent with stated user profile
All automated alerts are reviewed by trained compliance personnel. Alerts are categorised, investigated, and resolved in a timely manner. Where investigation reveals genuine cause for concern, the matter is escalated in accordance with our Suspicious Activity Reporting procedures.
Where we know, suspect, or have reasonable grounds to suspect that a person is engaged in money laundering or terrorist financing, we are required by law to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) via the UK Financial Intelligence Unit.
All employees who encounter or suspect suspicious activity must report their concerns immediately to the designated Money Laundering Reporting Officer (MLRO). Internal reports should be made without alerting the subject of the investigation (tipping off).
The MLRO reviews all internal reports and determines whether a SAR should be submitted to the NCA. The MLRO maintains a register of all internal reports received and the outcome of each review.
Where the MLRO determines that a SAR is warranted, it is submitted to the NCA promptly. Where required, the Company obtains a defence against money laundering (DAML) consent before proceeding with a transaction.
It is a criminal offence to disclose to the subject of a SAR, or to any third party, that a report has been made or that an investigation is underway. All staff are trained on tipping-off restrictions and the importance of maintaining confidentiality.
We maintain a strict non-retaliation policy. Any employee who makes a report in good faith is fully protected and will not face any adverse consequences as a result of raising concerns.
We maintain comprehensive records in compliance with applicable legal requirements. Our record-keeping obligations include:
We retain copies of all documents obtained for identity verification and due diligence purposes for a minimum of five years from the date the business relationship ends, or five years from the date of the transaction, whichever is later.
We maintain records of all transactions, including the date, amount, nature, and parties involved, for a minimum of five years.
Records of all internal suspicious activity reports and any SARs submitted to the NCA are retained for a minimum of five years.
Records of all AML training undertaken by staff, including dates, content, and attendees, are maintained for a minimum of five years.
All records are stored securely with appropriate access controls. Records are maintained in a format that can be retrieved and provided to the competent authorities upon request without undue delay.
Record keeping is conducted in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Records are not retained for longer than necessary.
We are committed to ensuring that all relevant personnel are appropriately trained to understand and fulfil their AML obligations. Our training programme includes:
All new employees in roles with AML responsibilities receive AML training as part of their induction. Training covers the legal and regulatory framework, company policy and procedures, and how to identify and report suspicious activity.
All relevant staff receive regular refresher training to keep pace with regulatory developments, emerging typologies, and updates to internal procedures. Training is conducted at least annually and more frequently where significant changes occur.
Training is tailored to the specific responsibilities of different roles within the organisation. Senior management, compliance staff, and customer-facing roles receive training appropriate to their level of exposure and responsibility.
Completion of all AML training is recorded and monitored. Failure to complete required training is escalated to management.
Beyond formal training, we foster a culture of compliance awareness throughout the organisation. Staff are encouraged to ask questions, raise concerns, and report suspicious activity without fear of reprisal.
REDDY STUDIOS LTD has appointed a designated Money Laundering Reporting Officer (MLRO) who bears primary responsibility for the Company's AML compliance programme.
• Receiving and reviewing internal suspicious activity reports from staff • Determining whether SARs should be submitted to the National Crime Agency • Overseeing the implementation and maintenance of AML policies and procedures • Ensuring that appropriate AML training is provided to all relevant staff • Maintaining required records and registers • Reporting to senior management and the Board on AML matters • Staying abreast of regulatory developments and updating the AML framework accordingly • Liaising with regulators, law enforcement, and external advisors as required
A Deputy MLRO has been appointed to fulfil the MLRO's functions in their absence, ensuring continuity of AML oversight at all times.
The MLRO has direct access to all information necessary to perform their duties and reports directly to the Board of Directors. The MLRO has the authority to suspend or terminate customer relationships where necessary to manage AML risk.
The MLRO can be reached through the Company's internal compliance channels. For external inquiries, please contact us via the details provided in Section 15.
We conduct and maintain a comprehensive AML risk assessment covering our products, services, customers, delivery channels, and geographic exposures. Our risk assessment framework includes:
We assess the inherent AML risks associated with our business model and operating environment. This assessment is reviewed and updated at least annually and whenever significant changes occur in the business or regulatory environment.
• Customer risk: demographics, geography, PEP exposure, industry • Product and service risk: nature of virtual currency, payment methods accepted • Delivery channel risk: online-only platform, international accessibility • Geographic risk: exposure to high-risk jurisdictions and sanctioned territories • Transactional risk: volume, frequency, and value of transactions
Based on the risk assessment, we implement proportionate controls to mitigate identified risks. Controls are regularly tested and evaluated for effectiveness.
Our Board of Directors has established a clear risk appetite for AML risk. We do not accept relationships or transactions where the residual AML risk cannot be adequately managed within our control framework.
The risk assessment and its outputs are fully documented and available for inspection by regulators upon request.
REDDY STUDIOS LTD is committed to full and transparent cooperation with all relevant regulatory and law enforcement authorities. Our commitment to regulatory cooperation includes:
We comply with all applicable AML legislation and regulatory guidance, including requirements issued by relevant UK authorities. We monitor regulatory developments and update our policies and procedures promptly when required.
We respond promptly and fully to all lawful requests for information from regulatory bodies, law enforcement agencies, and the National Crime Agency. We designate appropriate points of contact to handle regulatory inquiries.
We cooperate fully with regulatory examinations and audits, providing access to relevant records, systems, personnel, and premises as required.
We participate in industry initiatives to combat financial crime and share typological intelligence with appropriate counterparts, consistent with applicable law and data protection requirements.
In addition to SAR obligations, we fulfil all regulatory reporting requirements applicable to our business, including periodic compliance reports where required.
We maintain open lines of communication with relevant authorities and view regulatory cooperation as a cornerstone of our AML compliance programme.
We maintain a robust sanctions screening programme to ensure compliance with all applicable sanctions regimes, including those administered by:
All customers are screened against relevant sanctions lists at onboarding. Ongoing screening is conducted to capture additions to sanctions lists between periodic reviews.
We utilise automated sanctions screening tools that are regularly updated to reflect changes to applicable sanctions lists. Our screening tools are configured to identify direct matches as well as potential matches based on name variants and fuzzy matching techniques.
All sanctions alerts are reviewed promptly by trained compliance personnel. Confirmed matches result in immediate account suspension and, where required, the freezing of assets and reporting to OFSI or other relevant authority.
We maintain documented procedures for reviewing and clearing false positive alerts, ensuring that legitimate users are not unduly impacted while genuine matches are identified and actioned.
Any confirmed or probable sanctions match is escalated immediately to the MLRO and senior management. No transactions are processed for confirmed sanctioned parties, and we do not provide services to any person or entity subject to applicable sanctions.
This AML Policy is a living document that is reviewed and updated regularly to remain effective and compliant with applicable laws and regulations.
This policy is reviewed at least annually by the MLRO and senior management. Reviews are also triggered by:
Material changes to this policy require approval by the Board of Directors. Minor updates and clarifications may be approved by the MLRO. All changes are documented with the date of amendment and the nature of the change.
Previous versions of this policy are retained in our records for a minimum of five years.
All staff are notified of material changes to this policy. Where changes affect specific roles or procedures, targeted training is provided to ensure full understanding and implementation.
This policy was last reviewed and updated in February 2026.
For any questions, concerns, or reports related to this AML Policy or our compliance programme, please contact us through the following channels:
REDDY STUDIOS LTD 1 Ariel Way London United Kingdom W12 7SL Company Number: 16805476
For AML and compliance-related matters, please direct your enquiry to our compliance team. All enquiries are treated with the strictest confidence.
If you have concerns about suspicious activity on our platform, or if you are a third party with relevant information, please contact our MLRO through the compliance contact channel.
For general customer support enquiries, please visit our Help Centre or contact our support team through the platform.
If you have an unresolved concern, you may also contact the relevant regulatory authority:
For SAR-related matters: www.nationalcrimeagency.gov.uk
For sanctions-related matters: www.gov.uk/government/organisations/office-of-financial-sanctions-implementation
We are committed to responding to all compliance-related enquiries in a timely and professional manner.
© 2026 REDDY STUDIOS LTD. All rights reserved. This policy is subject to change. Please check back periodically for updates.