Anti-money laundering policy

This Anti-money laundering policy (the "Policy") sets out how Peeks guards the Service against Money Laundering, Terrorist Financing, Proliferation Financing and the evasion of Sanctions, and the obligations those measures place on you.

The Service is offered under the Peeks brand by 3-102-136856 Limitada, trading as Peeks Entertainment Limitada, a company organized under Costa Rican law with corporate identity number (cédula jurídica) 3-102-136856, whose registered address is Provincia 06 Puntarenas, Canton 11 Garabito, Jaco, Costado Este De La Municipalidad Garabito, Bufete Sanchez Chavarria, 61101, Costa Rica (the "Operator"). In this Policy, "Peeks", "we", "us" and "our" mean the Operator. The Operator holds a Costa Rican data processing license, which is described on the Company and license page.

This Policy forms part of the Terms of service (the "Terms"). By opening or using an Account you accept it. Capitalized words that this Policy does not define have the meanings given to them in the Terms.

As clause 1.3 of the Terms allows, this Policy overrides clauses 4.10, 7.1 to 7.12, 9.15 and 16.6 of the Terms wherever, and to the extent that, it deals differently with a matter of Money Laundering, Terrorist Financing, Proliferation Financing or Sanctions that those clauses also cover.

This Policy applies to every Account, including Access Code Accounts, and to every movement of value through the Service: Deposits and Withdrawals by every method the Cashier offers, Bets and their settlement, Tips, and transfers into and out of the Vault.

This Policy binds Peeks and its directors, officers, employees, contractors, agents and every other person acting on its behalf (together, "Staff"). A breach of this Policy by a Staff member is a disciplinary matter that may lead to dismissal or the termination of a contract, and to a report to the Competent Authorities where the law requires one.

This Policy takes effect on the date shown at the top of this page. It is governed by the laws of the Republic of Costa Rica.

The Identity verification policy, the Restricted countries and VPN policy, the Payments policy, the Skins trading policy, the Privacy policy and the Complaints policy set out how particular measures in this Policy are carried out, and each is read together with this Policy. Where one of them treats a matter of Money Laundering, Terrorist Financing, Proliferation Financing or Sanctions differently from this Policy, this Policy governs to the extent of the difference. The Privacy policy governs how personal data is processed, within the limits that clause 26.4 sets.

In this Policy the following words have the following meanings:

• "Applicable AML Law" means the laws, regulations, rules and binding instructions described in section 4, as amended or replaced from time to time, and any other law on Money Laundering, Terrorist Financing, Proliferation Financing or Sanctions that binds Peeks.
• "Business Risk Assessment" means the written assessment, kept under section 6, of the risks of Money Laundering, Terrorist Financing, Proliferation Financing and Sanctions evasion to which the Service is exposed.
• "Competent Authority" means the Financial Intelligence Unit, SUGEF, the ICD and PRODHAB, each as described in section 4, the courts, the Public Prosecutor's Office (Ministerio Público), the police and every other public body that Applicable AML Law or a Sanctions measure empowers to require information or action from Peeks.
• "Compliance Officer" means the person appointed under section 5 to own this Policy, to receive internal reports and to decide whether a matter is reported to the Financial Intelligence Unit.
• "Customer Due Diligence" or "CDD" means the measures in section 8 by which Peeks identifies a Player, verifies that identity, understands the purpose and intended nature of the Relationship and monitors it while it lasts.
• "Enhanced Due Diligence" or "EDD" means the additional measures in section 9.
• "FATF" means the Financial Action Task Force.
• "Financial Intelligence Unit" means the authority that receives reports of suspicious transactions under Applicable AML Law, identified in clause 4.3.
• "Know" and "knowledge" refer to actual awareness of a fact.
• "Linked Transactions" means two or more transactions that appear to be connected, whether carried out by one Player or by several, on one day or over a longer period, including transactions that appear to have been divided so that none of them reaches a threshold.
• "Management Body" means the body or person named in clause 5.1.
• "Money Laundering" means the conversion, transfer, concealment, disguise, acquisition, possession or use of property by a person who knows or suspects that it derives from a crime, whether that crime was committed in Costa Rica or abroad, or assisting any person to do any of those things, and includes the offense known in Costa Rica as legitimación de capitales.
• "Payment Partner" means a third party that processes Deposits or Withdrawals for Peeks, such as AssetPay, which processes Deposits and Withdrawals of Skins. The Cashier shows the methods offered at any time.
• "Player" means any individual who holds an Account or applies to open one, including you.
• "Politically Exposed Person" or "PEP" has the meaning given in section 10.
• "Proliferation Financing" means providing funds, other assets or financial services, in breach of law, toward weapons of mass destruction, being nuclear, chemical or biological weapons and the means of delivering them, whether for their development, making, acquisition, possession, shipment, export, stockpiling or deployment.
• "Reasonable grounds" to know or suspect exist where a reasonable person who held the same information would know or suspect.
• "Relationship" means the business relationship between Peeks and a Player. It begins when the Player opens an Account and ends once the Account has been closed and every amount owed by or to the Player has been settled or dealt with under section 21.
• "Sanctions" means the economic and financial sanctions, embargoes, asset freezes and other restrictive measures described in section 11.
• "Sanctioned Person" means any individual or entity named on a Sanctions list that Peeks applies, any person owned or controlled by or acting for such an individual or entity, and any person who normally lives in a country or territory under comprehensive Sanctions.
• "Source of Funds" means the origin of the particular money or Skins a Player uses with the Service.
• "Source of Wealth" means the origin of a Player's total wealth, being the activities through which the Player came to own the money and other assets the Player holds.
• "Staff" has the meaning given in clause 1.6.
• "Suspect" and "suspicion" refer to a belief, resting on facts, that something may be so. A suspicion goes beyond speculation, but it need not be capable of proof.
• "Suspicious Activity" means any transaction, attempted transaction or conduct that gives grounds to know or suspect Money Laundering, Terrorist Financing, Proliferation Financing, Sanctions evasion or the presence of the proceeds of any other crime.
• "Terrorist Financing" means providing or collecting funds or other assets by any means, directly or indirectly, with the intention or the knowledge that they will be used, in whole or in part, to carry out a terrorist act, by an individual terrorist or by a terrorist organization, whether or not they are linked to a specific act.
• "Verification Level" has the meaning given in the Terms; section 8 sets out what each Verification Level involves.

Access Code Account, Balance, Bet, Cashier, Coin, Deposit, Deposit limit, Digital Currency, Launch Date, Masking Tool, Maximum Payout, Network Check, Restricted Territory, Round, Step-up Check, Tip, Trade URL, Vault, Wagering Requirement, Winnings and Withdrawal have the meanings given in the Terms. Identity Partner, Open Round and Recorded Debt also have the meanings given in the Terms. Decline, Linked Steam Account, Marketplace Item, Reversal, Stock Item, Trade and Trade Offer have the meanings given in the Skins trading policy. As clause 8.5 of the Restricted countries and VPN policy provides, iCloud Private Relay used on its own is not a Masking Tool.

In this Policy the singular includes the plural; "including" and similar words do not limit the words that precede them; a reference to a law includes that law as amended or replaced; and headings do not affect interpretation.

The purposes of this Policy are to:

• refuse business with any person Peeks cannot identify, with Sanctioned Persons and with persons Peeks knows or suspects to be engaged in crime;
• know who holds each Account and where the money and Skins used on it come from;
• detect Suspicious Activity, including fraud connected with Deposits and Withdrawals, and report it to the Financial Intelligence Unit;
• keep records from which any transaction can be reconstructed and evidenced; and
• comply with Applicable AML Law and take account of the recommendations of FATF.

Money Laundering commonly passes through three stages: placement, layering and integration. On the Service, placement can take the form of a Deposit of Skins bought with stolen payment cards or other criminal proceeds, or of Digital Currency drawn from such proceeds; layering, the movement of that value through Bets that carry little risk, through Tips between Accounts or through rapid Deposits and Withdrawals; and integration, its Withdrawal in a form that looks like ordinary Winnings. The controls in this Policy are designed to interrupt each stage.

Peeks applies this Policy whatever the amount concerned. The thresholds it sets are the points at which particular measures become mandatory, and they do not limit Peeks' right to apply any measure at a lower amount.

Peeks declines a transaction, or ends a Relationship, where it cannot reconcile the transaction with what it knows about the Player. No commercial consideration and no length or size of Relationship overrides that rule.

Peeks does not provide banking, payment, money transfer, currency exchange or custody services. Where a Balance is held in more than one Coin or method, value moves between them only within the Player's own Account and only as clause 8.10 of the Terms provides, so a Player cannot move value between Coins and a move between Coins is made only by arrangement with Support. No such move is an exchange service. A Balance is not a deposit with a bank, earns no interest and may be used only to place Bets on the Service, to send Tips, to move money into the Vault and to withdraw as the Terms allow.

Peeks does not lend money to Players and does not accept a Bet that the Balance cannot cover.

Terrorist Financing and Proliferation Financing do not depend on the proceeds of crime: value of lawful origin can be sent to a terrorist or to a weapons program. Reviews under this Policy therefore look at where value goes as well as at where it comes from, including which Accounts receive an Account's Tips and where its Withdrawals are sent, and a suspicion of either offense is not set aside because the amount is small or its source is lawful.

The Operator is a company organized under the laws of the Republic of Costa Rica. It applies the measures in this Policy to meet its duties under Law 7786 on narcotics, psychotropic substances, drugs of unauthorized use, related activities, money laundering and terrorist financing, as amended by Laws 8204 and 9449, and under the regulations made under it.

Applicable AML Law places obligations on persons who operate physical or online casinos and other games of chance, including registration with the General Superintendency of Financial Entities (Superintendencia General de Entidades Financieras, "SUGEF") and compliance with the rules SUGEF issues for such persons.

Peeks reports Suspicious Activity to the Financial Intelligence Unit (Unidad de Inteligencia Financiera) of the Costa Rican Institute on Drugs (Instituto Costarricense sobre Drogas, "ICD").

Peeks applies the targeted financial sanctions adopted by the United Nations Security Council, which bind the Republic of Costa Rica, as clause 11.2 sets out.

Peeks takes account of:

• the FATF Recommendations, in particular Recommendation 10 on customer due diligence, Recommendation 11 on record keeping, Recommendation 12 on politically exposed persons, Recommendation 15 on new technologies, Recommendations 20 and 21 on reporting suspicious transactions and on tipping-off, and Recommendations 22 and 23, which extend those measures to casinos;
• the public statements in which FATF identifies high-risk jurisdictions and jurisdictions under increased monitoring;
• the work of the Financial Action Task Force of Latin America (GAFILAT), of which Costa Rica is a member; and
• the guidance of FATF on the risk-based approach for casinos and on politically exposed persons, and the reports of FATF and GAFILAT on how casinos and online gambling are misused.

Peeks processes personal data under this Policy in accordance with Law 8968 on the protection of persons with regard to the processing of their personal data and its regulation, under the supervision of the Agency for the Protection of the Data of Inhabitants (PRODHAB). Section 26 sets out how.

Where the law of a country from which a Player uses the Service, or in which a Payment Partner operates, imposes a stricter requirement on a transaction, Peeks may apply that stricter requirement.

A change in Applicable AML Law binds Peeks and Players from the date it takes effect, whether or not this Policy has yet been updated to reflect it.

The Compliance Officer follows the publications of the Financial Intelligence Unit, SUGEF, the ICD, FATF and GAFILAT, and the Sanctions lists named in clause 11.2.

When Applicable AML Law or this Policy changes, Peeks updates the procedures that Staff follow, the standard replies that Support uses and every other policy on the Site that depends on the change. A Player whose country of residence becomes a Restricted Territory is dealt with as clause 4.7 of the Terms provides, unless a Sanctions measure requires the Balance to be frozen.

The governing body of the Operator (the "Management Body") is responsible for this Policy. The Management Body approves this Policy and the Business Risk Assessment, appoints the Compliance Officer, gives the Compliance Officer the authority, independence, people, systems and budget the role requires, and receives and acts on the Compliance Officer's reports.

Peeks appoints a Compliance Officer, who is the compliance officer (oficial de cumplimiento) of Peeks for the purposes of Applicable AML Law. The Management Body designates a deputy, who acts whenever the Compliance Officer is absent or has a conflict of interest.

The Compliance Officer:

• owns this Policy and the procedures that implement it, and proposes changes to the Management Body;
• maintains the Business Risk Assessment and the method used to rate Players;
• decides whether an Account rated high risk may continue, and approves each Account held by a PEP;
• receives internal reports of Suspicious Activity, decides whether to report to the Financial Intelligence Unit and files those reports;
• acts as the point of contact for the Financial Intelligence Unit, SUGEF and other Competent Authorities;
• decides on restrictions, freezes, releases and closures made for compliance reasons;
• oversees any Sanctions and PEP screening and the handling of possible matches;
• organizes Staff training and keeps its records; and
• reports in writing to the Management Body on the operation of this Policy, as clause 5.14 describes, at the intervals Applicable AML Law requires and in any event at least once a year, and without delay on any matter of material risk.

The Compliance Officer has direct access to the Management Body, unrestricted access to every record, system and Staff member of Peeks, and the authority to suspend any Account or transaction. No person may instruct the Compliance Officer to file or not to file a report, and no Staff member may obstruct or delay a report.

Every Staff member must read and apply this Policy, raise any knowledge or suspicion of Suspicious Activity under section 22, cooperate with the Compliance Officer and keep confidential every matter covered by section 24.

Support Staff may collect information and documents and may tell a Player what Peeks needs. Support Staff may not lift a restriction placed for compliance reasons, release a withheld Withdrawal, change verified identity details or decide whether a matter is reported. Those decisions belong to the Compliance Officer.

Staff access to the data and tools of the Service is controlled by role. Reading a Player's personal data, reading the ledger, reading the audit log, opening an investigation and suspending an Account are separate permissions, each granted only to the roles that need it. Sensitive staff actions require the Staff member to pass a fresh identity check, and every staff action that changes an Account is recorded in the audit log under the name of the Staff member who took it.

Staff move money on an Account only through recorded commands, each of which carries a written reason. A command that adds money to an Account, writes off a Recorded Debt or overrides the settlement of an item takes effect only once a second Staff member has approved it, whatever the amount; a refund, or the attachment to an Account of a Deposit that could not be matched to one automatically, needs that approval above a set amount. Each Staff member who issues such commands is subject to a daily limit. Staff who hold the owner role are exempt from the second approval and from the daily limit. No Staff member may move money on his or her own Account. These commands come into use with the Skins cashier.

Where Peeks relies on a third party for part of its measures, such as the Identity Partner, a screening provider or a Payment Partner, Peeks remains responsible for compliance with this Policy. Peeks chooses such providers after reviewing their capability and reputation, requires them by contract to protect personal data and to give Peeks access to the records they hold for it, and checks the results they return.

A Staff member must not deal with an Account held by a relative or by any person with whom the Staff member has a personal or financial connection, and must declare any such connection to the Compliance Officer. Where the Terms allow a Staff member to hold an Account, that Account is subject to this Policy like any other and is reviewed by a different Staff member.

The Compliance Officer is a senior person who has passed the checks in clause 27.3 and who has the knowledge of Applicable AML Law and of the Service that the role demands. No target, bonus or other pay of the Compliance Officer depends on Deposits, Bets or revenue, and the Compliance Officer holds no role in marketing or in efforts to retain Players. A person outside Peeks may fill the role only under a contract that gives that person the access, authority and independence that this section gives the Compliance Officer.

The Compliance Officer may give any Staff member instructions on a matter that this Policy covers, and those instructions bind the Staff member. The Compliance Officer may use the access in clause 5.4 at any time and without notice, and every Staff member answers the Compliance Officer's requests without delay.

The Management Body records each appointment and each removal of the Compliance Officer and of the deputy, with the reasons, and gives any notice of it that Applicable AML Law requires. No person may dismiss, demote or otherwise disadvantage the Compliance Officer for making a report, or for deciding not to make one.

Each report of the Compliance Officer to the Management Body under clause 5.3 states at least:

• the number of internal reports received and of reports made to the Financial Intelligence Unit;
• the cases of Enhanced Due Diligence and their outcomes;
• the possible Sanctions and PEP matches and how each was resolved;
• the state of Staff training and any change to the Business Risk Assessment;
• the findings of the latest independent review under clause 27.4 and the work still open on them; and
• the people, systems and budget the role requires.

Before Peeks engages a Payment Partner, a Game Aggregator, a Studio, or a provider of identity verification, screening, network intelligence or hosting, and again at intervals while the engagement lasts, Peeks:

• establishes who owns and controls the provider;
• screens the provider and its owners against the Sanctions lists in clause 11.2;
• confirms that the provider holds any license its activity requires;
• where the provider handles value or Player data, reviews its controls against Money Laundering, fraud and Sanctions evasion, including, for a Payment Partner, the checks it makes on the sellers whose items fill Withdrawals; and
• searches for adverse media about the provider.

Where a provider's controls prove inadequate or its risk rises, Peeks adds controls of its own, suspends the feature that depends on the provider or ends the engagement.

Peeks applies a risk-based approach. It identifies and assesses the risks to which it is exposed and applies measures in proportion to them, stronger where the risk is higher, and never weaker than Applicable AML Law requires.

The Business Risk Assessment considers at least the following:

• customer risk: the profile, conduct and status of Players, including PEPs and persons connected with sectors of higher risk;
• geographic risk: the countries in which Players live and from which they connect, and the countries in which Peeks' providers operate;
• product risk: the Games offered, their speed and house edge, Tips and the Vault;
• payment risk: the methods by which value enters and leaves the Service, being the methods the Cashier offers, such as Skins through AssetPay and Digital Currency where the Cashier accepts it;
• channel risk: the Service is offered online only, and every Relationship is established without the Player being physically present;
• technology risk: the means by which Players may hide their identity or location, or automate their play, including the takeover of Accounts and of Steam accounts, identities assembled from a mix of real and invented details, and photographs or video made or altered by software to pass an identity check; and
• supplier risk: the Payment Partner, the Game Aggregator, the Studios and the other providers on whose results the controls in this Policy depend.

The Business Risk Assessment records in particular the following features of the Service that raise risk:

• Skins carry value outside the Service and can be bought, sold and traded on markets that Peeks does not control, including with stolen payment cards or through compromised Steam accounts;
• Deposits of Counter-Strike 2 Skins are subject to Steam's Trade hold, and a Trade can suffer a Reversal after it completes;
• Digital Currency, where the Cashier accepts it, can move quickly between countries and through services that hide where it came from;
• Originals settle in seconds and some carry a low house edge, so that value can be turned over many times at little cost;
• Tips move value directly between Accounts; and
• Studio games are supplied by third-party Studios, which hold the records of their own results.

The Business Risk Assessment also records the features of the Service that reduce risk:

• the Cashier shows each Account's Balance and, where it is held in more than one Coin or method, the amount held in each, with every amount stated in dollars or shown at its dollar value;
• Peeks accepts no cash, no payment cards and no bank transfers, only the methods the Cashier offers, and Digital Currency is added to a Balance only through the Cashier;
• Skins can be deposited only from, and withdrawn only to, the Linked Steam Account;
• each Deposit must be wagered once before it can be withdrawn, under the Wagering Requirement in clause 9.30 of the Terms, and Withdrawals are made only by a method, and in a Coin, that clause 9.31 of the Terms allows;
• Tips are the only way value can move between Accounts, and they are limited and recorded;
• an Account can have only one live session at a time, and two-step login and Step-up Checks protect sensitive actions;
• the Network Check can screen the network a Player connects from, and the country rules of the Restricted countries and VPN policy apply to every connection; and
• every change to a Balance is recorded in an append-only ledger.

Peeks reviews and updates the Business Risk Assessment at least once a year, before it introduces a new payment method, a new type of Game, a new way to move value between Accounts or a new technology, and after any significant incident or change in Applicable AML Law.

Peeks gives each Account a risk rating of low, medium or high. The rating takes account of the factors listed in section 35 and is recorded with the reasons for it. The rating determines the level of Customer Due Diligence applied and the intensity of monitoring, as clause 6.10 sets out.

A rating is reviewed whenever an event changes the risk, such as a Network Check finding, a change in the pattern of Deposits or Withdrawals, a Sanctions or PEP match, adverse media, a Reversal or a change of country. A Player rated high risk may continue to use the Service only with the approval of the Compliance Officer.

Some risks are unacceptable to Peeks whatever measures could be applied to them. Section 7 lists the persons Peeks does not accept.

Each Account receives its first rating when the Player completes Verification Level 1.

Each rating carries the following measures:

• low: the Customer Due Diligence in section 8 and the monitoring that applies to every Account;
• medium: Verification Level 2 before the next Withdrawal whatever the amount, where Peeks asks for it, and closer review of Withdrawals and Tips; and
• high: Enhanced Due Diligence, including Source of Funds and Source of Wealth, and approval of Withdrawals where Peeks requires it under clause 20.6.

Peeks applies no simplified due diligence. A low rating never removes a measure that this Policy applies to every Account.

The Management Body sets Peeks' risk appetite in writing and reviews it with each Business Risk Assessment. The statement identifies the risks Peeks accepts, the risks it accepts only subject to stated controls, and the risks it refuses, which include the persons listed in section 7.

For each category of risk in clause 6.2, the Business Risk Assessment records the risk before controls, the controls applied, the risk that remains and whether that remaining risk falls within the risk appetite. Where it does not, the Management Body adds controls, or changes or withdraws the Game, payment method or feature concerned. The method of assessment is written down and kept with each version of the Business Risk Assessment.

Peeks rates countries using the lists and mutual evaluations of FATF and GAFILAT, the Sanctions that apply to each country, published measures of corruption and organized crime, and each country's own law on online gambling.

Peeks opens an Account only for an individual who:

• is at least 18 years old, or any higher age that the law of the place where the individual lives or is present sets for gambling, and has full legal capacity;
• acts on his or her own behalf and for his or her own benefit;
• is not resident in, and does not use the Service from, a Restricted Territory;
• is not a Sanctioned Person; and
• is not barred from the Service by the Terms.

Peeks does not accept, and closes any Account found to be held by or for:

• a person under the age set in clause 7.1;
• a company, partnership, trust, foundation, association or any other entity or arrangement, or a person acting as agent, nominee, trustee or intermediary for another;
• a Sanctioned Person, or a person acting for one;
• a person resident in a Restricted Territory;
• a person who gives false, stolen or borrowed identity details;
• a person whom Peeks knows or suspects to be involved in Money Laundering, Terrorist Financing, Proliferation Financing, fraud, corruption, drug trafficking, cybercrime or any other serious crime;
• a person whose Account Peeks has closed for a breach of this Policy, or a person opening an Account on that person's behalf; or
• a person who offers to open, sell, buy, rent or lend an Account or a Steam account.

No Account may be anonymous or held under a fictitious name. A username is a display name chosen by the Player. Peeks may require a Player's identity details at any time and, once they are given, holds them behind the username.

Each Player may hold one Account. Peeks closes any additional Account and may treat an attempt to hold more than one as Suspicious Activity.

To register, a Player gives an email address, a username of 3 to 20 characters and a password of at least 12 characters, confirms that he or she is 18 or older and accepts the Terms. A Player may also enter a referral code, which earns no reward. Peeks may ask for the details of Verification Level 1 at any time.

Peeks may refuse to open an Account, or to accept a Deposit or a Trade, without giving its reasons where giving them would breach Applicable AML Law or prejudice the prevention or detection of crime.

Access Code Accounts keep only their login on the Launch Date, and the amounts they were given to play with cannot be withdrawn. Amounts that Peeks added to any Account before the Launch Date, such as starting amounts and prizes, are not funds of the Player and are dealt with as the Terms provide.

Peeks has no affiliate program and pays no person a reward for each Player introduced. No introducer, agent or other intermediary may open, fund or operate an Account for another person.

A Player who uses a Masking Tool, such as a VPN, a proxy, Tor or a hosting network, to hide his or her identity or location, or who uses the Service while present in a Restricted Territory, is dealt with as the Restricted countries and VPN policy provides, and Peeks may close the Account. A Player who declines or fails Customer Due Diligence is dealt with under clauses 8.9 and 8.16.

A Player must complete Verification Level 1 before every Deposit, and make any declaration that clause 10.4 requires before the first Deposit. Peeks may ask a Player to complete Verification Level 1 at any time, including before a Tip. Peeks may screen the Verification Level 1 details under sections 10 and 11, and accepts no Deposit while a possible match is under review.

Peeks may compare the details, devices and networks of new and existing Accounts, including Accounts closed under this Policy, to find any person who holds more than one Account or who returns after a closure. A shared device, network or address does not on its own show that two Accounts belong to one person. Before acting under clause 7.4, Peeks may ask the Players concerned to show that the Accounts belong to different people and are used separately, and it considers what they provide, unless Applicable AML Law or a Sanctions measure requires Peeks to act at once. Peeks may limit Tips between Accounts that share a device, a network or an address.

Customer Due Diligence consists of:

• identifying the Player and confirming that identity against reliable documents, data or other information that come from a source independent of the Player;
• establishing the purpose and intended nature of the Relationship, which for every Account is recreational play on the Service, and understanding the Player's expected activity;
• where Peeks considers it necessary, checking the Player against Sanctions lists, PEP data and adverse media;
• monitoring the Relationship and the transactions carried out in it while it lasts; and
• keeping the information and documents obtained up to date.

Identity verification is organized in four Verification Levels, each building on the one before it:

• Verification Level 1 consists of the personal details the Player gives on the Verification tab of the Settings page: first and last names, date of birth, street address, city, state or region, country and postal code. The date of birth must show an age of at least 18, and the Player must also meet any higher age that clause 7.1 sets, including a higher minimum age set for a country under clause 2.5 of the Restricted countries and VPN policy. The names and country are stored encrypted, and the other details are sealed so that the Site cannot read them back.
• Verification Levels 2 to 4 are described in the Identity verification policy.

Verification Levels 2 to 4 are completed through the Identity Partner, which examines the documents and data supplied and returns its findings to Peeks. Peeks takes the decision on verification. The Identity verification policy sets out each Verification Level and the verification process in more detail.

The Player cannot change the Verification Level 1 details on the Site once they are given. A correction, such as a change of name or address, is made through Support and, once verification beyond Verification Level 1 has begun, only on production of evidence. A correction may require the Player to complete a Verification Level again.

Peeks requires Customer Due Diligence beyond Verification Level 1:

• before a Deposit that brings the Account's Deposits in the last 30 days to $2,000 or more, and before a Deposit or Withdrawal by a method that the Cashier shows as needing a verified identity, in which case Verification Level 2 must be complete first;
• before a Deposit that brings the Account's Deposits, together with the Tips it has received, to $10,000 or more in the last 30 days or to $25,000 or more in the last 365 days, in which case Verification Level 4 must be complete first;
• whenever Peeks knows or suspects Suspicious Activity, whatever the amount;
• whenever Peeks doubts the truth or adequacy of identity details obtained earlier;
• when an Account is rated high risk or Enhanced Due Diligence applies;
• when a Network Check finding, a country mismatch or another indicator in section 34 is recorded;
• when a Competent Authority asks for it;
• when the Payment Partner or a Studio asks for it in connection with a Trade or a Round;
• when the Player asks to recover the Account, in particular without the authenticator app or the recovery codes;
• after repeated failed attempts at a Verification Level;
• at random, on Accounts selected without any indicator; and
• at any other time Peeks considers it necessary to comply with this Policy, whatever the Player's history, Balance or standing.

Each amount in this clause counts the new Deposit and any Deposit still under way, and a Verification Level that has started but is not complete counts as the Verification Level below it, as clause 6.4 of the Identity verification policy explains. Peeks may treat Linked Transactions as one, and may ask for Verification Level 3, or for any Verification Level before these amounts are reached, at any time.

Peeks may allow a Player to continue to play while Customer Due Diligence is in progress, and may hold any Withdrawal until it is complete. Where the circumstances call for it, Peeks may also suspend Deposits, Bets and Tips until it is complete.

A Player must supply the information and documents Peeks asks for within the period Peeks sets in its request. Peeks may extend that period where the Player shows good reason.

Peeks may verify identity details electronically against independent databases, through the Identity Partner or another reliable source, in addition to or instead of examining documents.

Where Customer Due Diligence cannot be completed, because the Player declines to provide what is asked for, has not provided it when the period in clause 8.7 ends, provides it incomplete or provides material Peeks cannot verify, Peeks carries out no further transactions on the Account while that remains the case, may end the Relationship and considers whether a report to the Financial Intelligence Unit is required. Declining to provide information is not of itself treated as evidence of crime; Peeks weighs it together with everything else it knows.

Peeks keeps the information it holds on each Player up to date. A Player must tell Peeks promptly of any change in name, address, country of residence or PEP status. Peeks reviews each Account, in the manner described in clause 8.15, whenever an event described in clause 6.7 occurs. A review may lead Peeks to ask for documents again, including documents that have expired since they were provided.

Below the amounts in clause 8.5, every Player who makes a Deposit still completes Verification Level 1 under clause 7.10, and every Player remains subject to monitoring, to any screening Peeks carries out and to the Network Check while it runs.

Peeks does not rely on the checks of any other business, including those of a Payment Partner or of Steam, in place of its own Customer Due Diligence.

Section 36 lists the information and documents Peeks may request and the standards they must meet.

When Peeks asks for information or documents, it states in a single request everything it needs at that stage, and it asks again only where what was supplied is incomplete or raises a new question, or where the law or a further trigger in clause 8.5 requires it.

A full review of an Account:

• confirms that the Player's identity documents are still in date, and asks for new ones where they are not;
• may screen the Player again under sections 10 and 11;
• compares the Account's Deposits, Withdrawals, Tips, Vault movements and play with the profile Peeks holds;
• looks again at Source of Funds and Source of Wealth where the rating calls for it; and
• confirms or changes the rating, and records the reasons.

A Player may still complete Customer Due Diligence after the period in clause 8.7 has ended. Peeks considers what arrives late, including whether the delay itself gives cause for concern, and lifts the restriction under clause 8.9 once the checks are complete.

Peeks may search for adverse media about a Player, through a screening service or public sources, including:

• when verification beyond Verification Level 1 takes place;
• at each full review under clause 8.15;
• when the Account's rating rises; and
• when an indicator in section 34 is recorded.

The Compliance Officer reviews each result and decides whether it concerns the Player, how reliable and how recent its source is, and whether the conduct it reports bears on Money Laundering, Terrorist Financing, fraud or another serious crime. An allegation that is unproven, or that cannot be tied to the Player, is not of itself a finding. The decision is recorded with its reasons, and may lead to Enhanced Due Diligence, a new rating or the end of the Relationship.

Peeks applies Enhanced Due Diligence:

• to every Account rated high risk;
• to PEPs, their family members and their close associates, as section 10 provides;
• to Players connected with a country that FATF identifies as under increased monitoring, or that the Business Risk Assessment rates as high risk;
• to transactions that are complex or unusually large, or that follow an unusual pattern, and that have no apparent economic or lawful purpose;
• when the Player's activity is out of line with the Source of Funds or with the profile Peeks holds;
• when the country the Player declares, the country the Player connects from and the country shown by the Player's documents do not match;
• when adverse media or other information links the Player to crime;
• when the ownership of the Linked Steam Account is in doubt;
• after a Reversal of a Deposit, after a Withdrawal is reversed by the Player or at the Player's request, or after a Deposit of Skins that Peeks believes to be stolen or taken from a compromised Steam account;
• where Accounts appear to act together, through Tips, Bets on opposing outcomes or shared details;
• after repeated Network Check findings on the Account;
• where a Competent Authority or the Payment Partner gives Peeks information that points to a higher risk; and
• when Withdrawals go to a destination other than the one from which the Deposits came, such as another Steam account or wallet.

Enhanced Due Diligence may include:

• further evidence of identity and address, or verification through a further independent source;
• evidence of Source of Funds and of Source of Wealth;
• information on the Player's occupation, the kind of work he or she does and income;
• the Player's national identity number or tax number, where the Player's country issues one;
• the Player's own estimate of the amounts he or she expects to deposit and to play each month;
• a written explanation of particular Deposits, Withdrawals, Tips or Bets, with evidence;
• a video call with the Compliance Officer, or with a Staff member the Compliance Officer designates, in which the Player shows the original identity document and answers questions about the Account;
• a review of the other Accounts, Steam accounts, devices and networks connected with the Account;
• the approval of the Compliance Officer before the Relationship begins or continues;
• closer monitoring, including review of transactions before they are released; and
• more frequent reviews of the Account.

While Enhanced Due Diligence is in progress, Peeks may restrict the Account in any of the ways described in section 21.

Where the results of Enhanced Due Diligence do not satisfy Peeks, Peeks ends the Relationship and considers whether a report to the Financial Intelligence Unit is required.

Every decision taken under Enhanced Due Diligence is recorded with its reasons.

Enhanced Due Diligence may be repeated, and completing it once does not limit what Peeks may ask for later.

A Politically Exposed Person is an individual who holds a prominent public function, or has held one, whether in Costa Rica, in another country or in an international organization. Prominent public functions include those of:

• heads of state, heads of government, ministers and deputy ministers;
• members of a national legislature or a comparable assembly, and members of the governing bodies of political parties;
• holders of senior regional or municipal office of comparable importance;
• judges of the highest courts, including supreme and constitutional courts, whose decisions are not ordinarily open to further appeal;
• members of audit courts and of the governing boards of central banks;
• ambassadors, chargés d'affaires and senior officers of the armed forces;
• members of the boards and senior management of enterprises owned by a state; and
• directors, deputy directors and board members of international organizations.

Holders of middle-ranking or junior posts in these bodies are not PEPs for that reason alone.

The measures in this section also apply to a PEP's family members, meaning the PEP's spouse or a partner treated as a spouse, the PEP's children and their spouses or partners, the PEP's parents and any other relative within the degree of kinship that Applicable AML Law covers, and to the PEP's close associates, meaning persons known to own a legal entity or arrangement jointly with the PEP or to have any other close business relationship with the PEP.

Peeks accepts no Deposit from a PEP, or from a person to whom clause 10.2 extends this section, and pays no Withdrawal to either, until the Compliance Officer has approved the Account in writing, after Enhanced Due Diligence that establishes the Source of Wealth and the Source of Funds. The Account is then subject to enhanced monitoring for as long as the Relationship lasts.

A Player who holds a prominent public function, or who is a family member or close associate of a person who holds one, must tell Support before making a first Deposit, and must tell Peeks promptly of any change. A false declaration is a breach of this Policy.

Peeks may screen Players against PEP data when the Player gives the details of Verification Level 1, when verification beyond Verification Level 1 takes place and when identity details change.

A person who has ceased to hold a prominent public function continues to be treated as a PEP for as long as the risk requires, and in any event for the period Applicable AML Law sets.

The Compliance Officer reviews each possible PEP match by comparing the details in the PEP data with those Peeks holds, and may ask the Player for more information. A match that is ruled out is recorded with the reasons. A confirmed match leads to the measures in clause 10.3, and Peeks may hold Withdrawals until the approval in that clause is given. Where that approval is refused, Peeks ends the Relationship under section 21 and, unless section 21 provides otherwise, pays the Balance once the checks in section 20 are complete.

Peeks does not knowingly open or maintain an Account for a Sanctioned Person, accept a Deposit from one, pay a Withdrawal to one or allow a Tip to or from one.

Peeks applies the Sanctions of the United Nations Security Council, including the persons and entities on the consolidated list maintained under its resolutions, and the measures by which the Republic of Costa Rica gives effect to them.

Peeks may screen the name and any other name it holds for each Player, together with the Player's date of birth, country and the issuing country of any identity document, against the Sanctions lists it applies, when the Player gives the details of Verification Level 1, when verification beyond Verification Level 1 takes place and whenever identity details change, and may screen all Accounts again whenever a list it applies is updated. The Terms, the Privacy policy and the Identity verification policy refer to the times in this clause and in clause 10.5.

A possible match is reviewed by the Compliance Officer, who compares the identifying details on the list with those Peeks holds. A similar or identical name is not of itself a finding. Peeks may suspend the Account while the review is in progress. A match the Compliance Officer rules out is recorded with the reasons and the Account is restored. A confirmed match leads Peeks to freeze the Account and any Balance without delay and without notice to the Player, to report to the Competent Authorities and to deal with the funds only as they direct.

The Service may not be used by persons resident in, or physically present in, a Restricted Territory. Restricted Territories are defined in the Terms and set out in the Restricted countries and VPN policy. They include every country or territory under comprehensive Sanctions, and Peeks also treats as a Restricted Territory every jurisdiction that FATF has named as high-risk and subject to a call for action, as clause 3.6 of the Restricted countries and VPN policy sets out. A Player who travels to a Restricted Territory may not use the Service while there.

Peeks may compare the country of residence given at Verification Level 1 with the country shown by the Player's documents and with the country the Player connects from. A mismatch is reviewed and may lead to Enhanced Due Diligence or to the closure of the Account.

Peeks may switch the Network Check on or off. While it is on, it runs when a Player signs up, logs in, visits the Site while logged in, deposits and withdraws. It does not run when a Player places a Bet, opens a Game, sends a Tip, moves money to or from the Vault or links a Steam account.

The Network Check looks for Tor, a VPN, a proxy, a hosting network, iCloud Private Relay, and a difference between the time zone of the Player's device and the location of the network. While the Network Check is set to refuse, Tor, a VPN, a proxy and a hosting network block the action; otherwise they are only recorded. A time-zone difference is recorded for review and does not block on its own. Private Relay on its own is neither blocked nor recorded.

To run the Network Check, Peeks compares the network address with published lists of the address ranges used by VPNs, data centers, Tor exit points and iCloud Private Relay, which it refreshes regularly, and uses the country and the Tor indication reported by Cloudflare, which sits in front of the Site. The country reported by Cloudflare also decides the country rules in section 11, even while the Network Check is switched off.

When a blocking signal is found while the Network Check is set to refuse, the action is refused, and the Site shows a screen that asks the Player to switch the VPN or proxy off before trying again, as clause 6.5 of the Restricted countries and VPN policy describes.

Peeks keeps records of Network Check findings as section 7 of the Restricted countries and VPN policy describes, including the cases in which no record is made. Staff reviewing an Account see how many checks found a blocking signal and how many of those were refused, and, for the most recent recorded check, its time and signals and, where their role permits, its network prefix. Peeks does not keep the network address itself in these records.

Using a Masking Tool is a breach of this Policy and of the Terms, carries the consequences the Terms set out and may be treated as Suspicious Activity.

A Player who believes a block is mistaken may contact Support, and a member of Staff will review it.

Peeks asks a Player to establish the Source of Funds:

• under Enhanced Due Diligence;
• when Deposits are out of line with what Peeks knows of the Player's circumstances;
• when the Account's Deposits, together with the Tips it has received, reach $10,000 in 30 days or $25,000 in 365 days, at which point Verification Level 4 applies under clause 8.5; and
• at any other time Peeks has reason to doubt that the money or Skins used on the Account belong to the Player and come from a lawful source.

Peeks asks a Player to establish the Source of Wealth when the Player is a PEP, when the Account is rated high risk and when the Player's activity is significant in relation to what Peeks knows of the Player's wealth.

Evidence of Source of Funds and Source of Wealth may include:

• payslips, an employment contract or a letter from an employer;
• a tax return or a tax assessment;
• bank statements showing income or savings;
• the accounts of a business the Player owns, with evidence of the Player's share in it;
• documents recording the sale of property, shares or another asset;
• records of the sale of Skins or other digital assets and of the receipt of the proceeds;
• documents recording an inheritance, a gift or a legal settlement and, for a gift, a letter from the giver with evidence of where the giver's money came from;
• statements from an investment or pension account;
• statements of winnings from another gambling operator;
• documents recording a loan, where using the loan for this purpose is lawful, in which case the matter is also dealt with under clause 28.1;
• for Skins, the purchase and market history of the Steam account, receipts from the marketplaces where the Skins were bought and records showing how they were otherwise obtained; and
• any other evidence that establishes the lawful origin of the money or Skins concerned.

Evidence must be authentic, recent where relevant and consistent with the activity it is offered to explain. Peeks may verify it with the issuer or with another independent source, and may decline any explanation it cannot verify.

Peeks uses the evidence only for the purposes of this Policy and keeps it as section 25 requires.

A Player may cover entries on a bank or card statement that have nothing to do with the request, provided the name of the account holder, the issuer, the dates and the entries Peeks needs remain visible.

The Cashier shows each Account's Balance and, where it is held in more than one Coin or method, the amount held in each, with an amount held in a Coin shown at its dollar value, as clause 8.1 of the Terms describes. A move of value between Coins is made only as clause 8.10 of the Terms provides. The methods available for Deposits and Withdrawals, with their minimums, maximums and any conditions a method requires, are shown in the Cashier.

Deposits and Withdrawals are made only by the methods the Cashier offers, such as Skins for Counter-Strike 2 and Rust, processed by AssetPay, and Digital Currency where the Cashier accepts it. Peeks accepts no cash, payment cards, bank transfers, paper checks, money orders or prepaid vouchers, and makes no payment by any of them. Withdrawals are made only by a method, and in a Coin, that clause 9.31 of the Terms allows.

Where the Cashier offers Skins, deposited Skins pass to AssetPay, and their dollar value, priced as the Payments policy describes, is added to the Balance when the Deposit lands. Peeks does not hold Skins for Players. A Withdrawal is filled with a Marketplace Item or a Stock Item and sent to the Player as a Trade Offer, and its price is charged to the Balance. Fees are included in the prices shown, and where a Withdrawal costs less than the amount held for it, the difference returns to the Balance.

Unless the Cashier shows different limits when a Player starts, each Deposit and each Withdrawal of Skins must be worth at least $1.00 and no more than $5,000.00, a Deposit may contain up to 250 items and a Withdrawal up to 50, up to 5 Deposit Trade Offers may await acceptance at once, up to 10 Deposits may be started in any 5 minutes, and up to 3 Withdrawal Trades may be open at once, not counting a delivered Trade that is within its Trade hold. A Withdrawal that would need more than 3 Trades is refused. The Cashier shows the limits for every other method.

Deposits of Counter-Strike 2 Skins are subject to Steam's Trade hold. They are shown as held by Steam, with the date on which they will land, and at the date of this Policy nothing is added to the Balance before then. Deposits of Rust Skins are added when the Trade completes, but where AssetPay reports a hold on one, nothing is added and Staff review it. A Deposit that lands while the Account is suspended, restricted, on a Play break or in Self-exclusion, or over a Deposit limit or a cap set by Staff, is held apart from the Balance and recorded, and Staff are alerted and deal with it.

A Deposit that suffers a Reversal before it lands adds nothing to the Balance. Where a Reversal follows a Deposit that has landed, Peeks takes back from the Balance the amount the Deposit added, and any part the Balance cannot cover becomes a Recorded Debt. Peeks recovers a Recorded Debt before any Withdrawal, Tip or move of money into the Vault, and from each later Deposit when it lands, and Staff may also apply money held in the Vault to it. While any part of a Recorded Debt remains open, no Withdrawal, Tip or move of money into the Vault can be made.

A purchase of a Counter-Strike 2 Marketplace Item is canceled automatically if the seller has not sent the item within about 30 minutes, and a Rust Withdrawal waits for the seller to send the item. A declined Withdrawal is refunded to the Balance in full. At the date of this Policy, after 3 Declines of Marketplace Items within 7 days, new Withdrawals that include Marketplace Items are paused for a period, while Withdrawals of Stock Items stay open.

Where a Player reverses a delivered Withdrawal through Steam, or it is reversed at the Player's request, the Reversal is recorded and the Account is flagged for review. What returns to the Balance depends on what AssetPay refunds: where AssetPay reports a refund for the item, that amount returns, up to the amount paid; where it reports none, the amount paid for a Stock Item returns, and nothing returns for a Marketplace Item or a Rust item. Where a seller reverses a delivered Withdrawal, the amount paid for the item returns to the Balance, and Staff review a Reversal whose source is unclear. Where Steam reports that a delivered Counter-Strike 2 Withdrawal failed during its Trade hold, Peeks checks whether the item has left the Linked Steam Account's inventory, and where it has, the amount paid may return to the Balance after a review by Staff.

Peeks refuses Skins it knows or suspects to have been obtained through theft, fraud or the compromise of a Steam account, and may report them.

Peeks reconciles its records of Trades with those of AssetPay and investigates every difference.

Digital Currency is added to a Balance only through the Cashier, where the Cashier accepts it. Digital Currency that arrives in any other way, including through the Payment Partner that processes Skins, is never added to a Balance: Peeks records it, alerts Staff, refers it to the Compliance Officer and deals with it as Applicable AML Law requires.

A Payment Partner may apply its own checks to a Trade and may refuse one. Peeks may share with a Payment Partner the information needed to prevent fraud, Money Laundering and the misuse of Skins.

Before Peeks offers a new payment method, it updates the Business Risk Assessment and amends this Policy to cover the method.

The Service offers no way for Players to trade Skins with one another. Skins pass only between a Player's own Linked Steam Account and AssetPay.

Skins can be deposited only from, and withdrawn only to, the Linked Steam Account. That Steam account must belong to the Player and be registered to the Player and, for Withdrawals and Rust Deposits, must be protected by Steam Guard's mobile authenticator.

Linking a Steam account and setting or changing the Trade URL each require a fresh Step-up Check. At the date of this Policy, no Withdrawal can be made for 24 hours after a Steam account is linked or the Trade URL is changed.

An Account can have only one Linked Steam Account at a time. Once a Steam account has been linked to an Account, it cannot be linked to any other Account, even after the first Account unlinks it, unless Peeks releases it after a review.

A Player may not deposit from, or ask for a Withdrawal to, a Steam account belonging to another person, and may not use a Steam account that is shared, borrowed, rented or bought. Deposits from and Withdrawals to third-party accounts are refused.

Peeks may ask a Player at any time to show that he or she owns and controls the Linked Steam Account, including by providing screenshots or exports of the account's details and purchase history taken from within Steam, and may suspend Trades until the Player does so.

Where an Account has had more than one Linked Steam Account, Peeks may review any Withdrawal that would send value deposited from an earlier Steam account to a later one. Peeks may ask the Player to show ownership of both Steam accounts, and may require value, up to the amount of the Deposits made from an earlier Steam account, to be withdrawn to that account while it can still receive Trades.

A Tip is a gift of part of the Balance to another Player. Tips are the only way value moves directly between Accounts, and they are not a payment service.

A Tip must be for at least $1.00 and no more than $10,000, and a Player may send up to $50,000, and up to 100 Tips, in a day counted from 00:00 UTC, as clause 10.2 of the Terms sets out. Tips open once the Player has wagered $100, counted as clause 10.4 of the Terms describes, and a Tip may be sent only from the part of the Balance above the Wagering Requirement, as clause 9.30 of the Terms provides.

Sending a Tip requires a fresh Step-up Check: a two-step code or passkey check where the Player has set one up, and otherwise the Player's password. A Player cannot tip himself or herself, and cannot send a Tip during a Play break or Self-exclusion, while a Recorded Debt or a reversed Deposit is unsettled, from value added for a Skins Deposit that has not completed, while Peeks has restricted the Account or blocked Tips between the Accounts concerned, or from a place where play is closed, as clause 10.4 of the Terms sets out. Peeks refuses a Tip to an Account that is suspended, on a Play break, in Self-exclusion or under a restriction set by Staff.

Each Tip is recorded in the ledger against both Accounts, with its amount and time, and in the audit log.

A Tip may not be used:

• to pay for goods or services, or to settle a debt, wager or arrangement made outside the Service;
• to buy, sell or rent an Account, a Steam account or Skins;
• to move value on behalf of another person;
• to pass value to an Account that the sender also controls, or between Accounts that act together;
• to avoid Customer Due Diligence, a Withdrawal check, a limit or the Network Check; or
• to pass value to or from a Sanctioned Person or a person in a Restricted Territory.

Staff reviewing Tips look for patterns that suggest Money Laundering or collusion, including value passing in a circle between Accounts, many Accounts tipping one Account, one Account tipping many, Tips sent soon after a Deposit, Tips received and withdrawn without play, and Tips between Accounts that share details. Peeks may suspend the Accounts concerned and withhold the amounts concerned while it reviews them.

Value received as a Tip forms part of the recipient's Balance and is subject to every check that applies to a Withdrawal. Peeks may ask the recipient, the sender or both to establish the Source of Funds of tipped value.

The Vault holds money that the Player has moved out of the Balance, apart from play. It is not a separate account with Peeks, it earns no interest and only the Player may use it.

Moving money out of the Vault, or setting a lock on it, requires the Player's password or a fresh passkey check and, where two-step login is on, a fresh two-step code or passkey check. A Player may lock the Vault for a period of up to 24 hours, and an active lock cannot be shortened.

Amounts in the Vault remain subject to this Policy. They may be used to recover a Recorded Debt under clause 14.6, and they are restricted or frozen together with the Balance under section 21.

Staff reviewing an Account look at the use of the Vault together with Deposits and Withdrawals, including amounts moved into the Vault soon after a Deposit and later withdrawn without play.

A Bet must be a genuine wager, placed for entertainment and at a real risk of loss. A Bet placed to move value rather than to play is a breach of this Policy. Examples include Bets on outcomes that offset each other, placed through Accounts acting together, and Bets placed at the lowest risk a Game allows with no apparent purpose other than to make Deposits look like Winnings. Peeks may leave such Bets out of the count for the Wagering Requirement, as clause 9.30 of the Terms provides.

Each Deposit must be wagered once before it can be withdrawn, under the Wagering Requirement in clause 9.30 of the Terms, and Withdrawals are made only by a method, and in a Coin, that clause 9.31 of the Terms allows. A Withdrawal that follows a Deposit with little play may still be reviewed, and Peeks may apply Enhanced Due Diligence before paying it.

A single stake on an Original may not exceed $10,000, and the Maximum Payout of every Original is $1,000,000 for a single Bet, as clause 11.8 of the Terms sets out. A Bet that could pay more is refused before it is placed, so some selections accept only smaller Bets. Each Studio game carries the limits its Studio sets. A single win of more than $1,000,000 in a Studio game is not added to the Balance but held for review, and after the review $1,000,000, the amount of the Maximum Payout, is added to the Balance in its place, unless the review finds a malfunction or Prohibited Conduct, in which case clauses 11.14, 11.15 and 14.5 of the Terms apply. Staff are also alerted to every win of more than $10,000 in a Studio game, and Peeks may review any large win.

The results of Originals are set from server seeds committed before each Bet, and they can be checked with the Verifier on the Provably fair pages. Peeks keeps the Seeds and Round records from which any result of an Original can be recomputed. The results of Studio games are produced and recorded by the Studios that supply them.

Fun play involves no stake and no Balance, and nothing won in Fun play has value or can be withdrawn.

At the date of this Policy, Peeks offers no bonuses, promotions or referral rewards. Any promotion offered in the future will carry its own terms, and using a promotion to move value between Accounts, or to extract value without genuine play, is a breach of this Policy.

Every Account is monitored for the whole of the Relationship, through the controls built into the Service that clause 19.3 lists and through review by Staff of the records described in clauses 19.6 and 25.1, to detect activity that is unusual for the Player, that matches an indicator in section 34 or that is inconsistent with the information Peeks holds. A review may compare the Account's activity with that of similar Accounts and with the known methods of misusing online casinos and Skins.

Monitoring covers:

• Deposits and Withdrawals, including their size, frequency and timing;
• the prices at which Skins are deposited and withdrawn, compared with their market history;
• Bets, including stake size, choice of Game and house edge;
• Tips, and movements into and out of the Vault;
• Trades, and their Reversal, decline or cancellation;
• Steam account links and changes of Trade URL;
• changes to identity details, email address and password;
• the sessions, devices and networks used to reach the Account;
• messages exchanged with Support;
• alerts and reports from the Payment Partner and from Studios; and
• Network Check records.

Monitoring combines controls built into the Service with review by Staff. The built-in controls include the Verification Levels required before Deposits under clause 8.5, Deposit limits and the caps Staff may set under clause 9.19 of the Terms, the holding of a Deposit that lands over one of them or on a restricted Account, the limits on Trades, Tips and open Withdrawals, the $100 of play needed before Tips open, the limits on open Deposit Trade Offers and on the number of Deposits started in a short period, the pause on Withdrawals of Marketplace Items after repeated Declines, the wait after a Steam link or Trade URL change, the recording of the unpaid part of a reversed Deposit as a Recorded Debt, the country checks and, while it runs, the Network Check. Staff are alerted when a landed Deposit is reversed, when a Deposit is held, when a Deposit fails during the Trade hold, when a Player reverses a Withdrawal, when a Recorded Debt arises, when Digital Currency arrives through the Payment Partner that processes Skins, when a Studio win passes the amounts in clause 18.3 and when the limit on Declines is reached.

The Service records the result of the checks run on each Withdrawal. A Withdrawal of $2,000 or more, or one that takes the Account's Withdrawals in the last 24 hours above $10,000, is marked for review by the Compliance Officer or by a member of Staff the Compliance Officer designates. The mark does not of itself hold the Withdrawal, but Peeks may hold it under clause 20.3.

Peeks may treat Linked Transactions as one transaction when it applies a threshold, and Staff reviewing an Account look for transactions that appear to have been divided to stay below one.

Staff reviewing an Account have access to its Rounds, its ledger and its audit log, to its Trades with a full timeline of each, to its Tips and to its Network Check records.

A review ends with a recorded outcome: no further action, a request for information, Enhanced Due Diligence, a restriction under section 21, an internal report under section 22, or more than one of these.

Peeks reviews its monitoring controls as part of the Business Risk Assessment and adjusts them as the Service, its Players and the methods of misuse change.

The indicators in section 34 do not limit monitoring. Peeks reviews any activity that appears inconsistent with lawful recreational play, whether or not it matches a listed indicator.

Peeks compares the price of each deposited item with its recent sales on the markets where it trades, and refers a Deposit to Staff where an item's price is far above that history, or where the item trades too rarely for its price to be relied on.

The indicators and factors in sections 34 and 35 are examples. The rules, scores, settings and amounts that Peeks uses, beyond those this Policy states, are confidential, and Peeks does not disclose them, including in answer to a request for personal data, where disclosure would help a person get round them.

Passing an automated check does not prevent Peeks from reviewing the same matter by hand.

A decision under this Policy to suspend or close an Account, to freeze or withhold a Balance or to refuse a Withdrawal is taken by a member of Staff and not by an automated system, except for the automatic checks in clause 20.1, the built-in controls in clause 19.3, the country checks under section 11 and the blocks that the Network Check applies under section 12.

A breach of this Policy does not depend on a Withdrawal having been made or on any loss to Peeks. Peeks may act on an attempt, and on activity that the Player says was not meant to move value.

Before a Withdrawal is sent, the Service checks, among other things, that:

• the Player has passed a fresh Step-up Check;
• Withdrawals are open, the Account is not suspended and no restriction pauses its Withdrawals, and the Player meets the conditions the Cashier shows for the method, such as a verified email address or a Verification Level;
• the Withdrawal is within the limits in clause 14.4 and the Balance can cover it;
• no Recorded Debt is outstanding once any recovery under clause 14.6 has been made;
• for Skins, the Linked Steam Account can receive Trades, the wait under clause 15.2 has ended and, where Marketplace Items are chosen, no pause under clause 14.7 is in force; and
• while the Network Check runs and is set to refuse, it does not block the Withdrawal.

The Service also records the result of the further checks described in clause 19.4, including the country checks, for review by Staff. For Skins, before AssetPay completes the Trade, the Service checks again, among other things, that the items match the request and cost no more than the amount held for them, that the Account is not suspended, that no Recorded Debt is open and that Withdrawals have not been frozen.

A Withdrawal is paid only to a destination the Player owns, such as the Linked Steam Account or the Player's own wallet, and only by a method, and in a Coin, that clause 9.31 of the Terms allows. While the Wagering Requirement is above zero, only the part of the Balance above it may be withdrawn, as clause 9.30 of the Terms provides, except in the payout made when an Account is closed under clause 16.4 of the Terms. Peeks never pays a Withdrawal to a third party or in cash.

Peeks may hold a Withdrawal, or pause Withdrawals on the Account, while a check is completed, in particular where:

• Customer Due Diligence that applies under section 8 is not complete;
• the Withdrawal does not appear to fit the Account's history of play and Deposits;
• the review in clause 15.6 applies;
• the Account is rated high risk, in which case the Withdrawal may wait for approval under clause 20.6;
• the Payment Partner or a Studio is reviewing a Trade or a Round;
• information asked of the Player is still outstanding; or
• Peeks is waiting for the instructions of a Competent Authority.

Peeks tells the Player what it needs, except where doing so would breach section 24.

A Player on a Play break or in Self-exclusion may withdraw, subject to the checks in this section, but may not deposit.

The Balance of a suspended Account can be released only by Staff.

Where Peeks requires approval of a Withdrawal from an Account rated high risk, the Compliance Officer or a Staff member whom the Compliance Officer designates approves it. Before approving it, the approver checks that the Player's identity documents are still in date, asks for new ones where they are not, and confirms that the Withdrawal fits what Peeks knows of the Player.

Where Applicable AML Law requires it, or where Peeks has reasonable grounds under this Policy, Peeks may:

• refuse or hold a Deposit, a Trade, a Bet, a Tip or a Withdrawal;
• suspend the Account, or limit it to particular functions;
• freeze the Balance and any amount in the Vault; and
• close the Account.

A restriction placed while Peeks reviews an Account is a precaution. It is not a finding that the Player has done anything wrong.

A restriction does not cancel a Bet already placed, and open Rounds are dealt with as the Terms provide.

Where Applicable AML Law, a Sanctions measure or an order of a Competent Authority requires funds to be frozen, Peeks freezes them and releases them only when the law or the Competent Authority permits.

In any other case, once a review has ended, a Balance that Peeks is free to pay is paid by a Withdrawal by a method that clause 9.31 of the Terms allows. Peeks may withhold amounts that derive from a breach of this Policy, such as Winnings from Bets placed with funds of unlawful origin, to the extent the Terms and the law allow.

Peeks complies with orders and lawful requests of Competent Authorities, including courts, concerning an Account, including orders to freeze, seize or disclose.

When Peeks closes an Account under this Policy, it may be unable to give the reason. Peeks is not liable for loss caused by a delay, refusal, restriction or closure made in good faith to comply with this Policy or with Applicable AML Law.

A Player may ask Support to close the Account once open Rounds have finished. The Balance is then paid out under clause 16.4 of the Terms, after the checks in section 20. Closing an Account does not end a review that is in progress, release a frozen Balance or end Peeks' duty to keep records under section 25.

Failing to complete Customer Due Diligence does not forfeit a Balance. Unless Applicable AML Law, a Sanctions measure or a Competent Authority requires it to be frozen or dealt with in another way, the Balance remains recorded to the Player. A Balance that remains unclaimed is dealt with under clause 16.8 of the Terms.

When Peeks restricts an Account or holds a transaction under this Policy, it tells the Player that the restriction is in place, what it covers and what the Player can do, unless section 24 prevents it.

A Staff member who knows or suspects, or has reasonable grounds to know or suspect, that a Player or a transaction is involved in Suspicious Activity must report it to the Compliance Officer without delay and before taking any further action on the Account that could alert the Player.

An internal report states who is involved, what happened, when and where it happened, why it is suspicious and which records were consulted. Staff must not investigate beyond what is needed to make the report, and must not discuss it with anyone other than the Compliance Officer.

The Compliance Officer acknowledges each internal report, examines it and records the decision taken and the reasons for it, whether or not a report is made to the Financial Intelligence Unit.

No Staff member suffers any detriment for making an internal report in good faith.

A concern that involves the Compliance Officer is reported to the deputy. A concern that involves a member of the Management Body or the owner of the business may be reported to the Compliance Officer and, at the same time, to the independent reviewer under clause 27.4.

Staff may make an internal report with or without giving their name. A report made in good faith is protected whether or not a crime is later shown.

Peeks keeps confidential the identity of every person who makes an internal report and of the person who signs a report to the Financial Intelligence Unit, and discloses it only to a Competent Authority that requires it.

The Compliance Officer files a suspicious transaction report with the Financial Intelligence Unit for every transaction or attempted transaction that Peeks knows or suspects to be connected with Money Laundering, Terrorist Financing or Proliferation Financing, whatever its amount, within the time Applicable AML Law sets.

Peeks also makes every other report Applicable AML Law requires, including reports of transactions above set amounts, reports of assets frozen under Sanctions and any periodic return, including a nil return for a period in which there was nothing to report.

Peeks cooperates with the Competent Authorities, including the Financial Intelligence Unit, SUGEF and the courts, and answers their lawful requests for information within the time they set. Every such request is passed to the Compliance Officer, who verifies that it is genuine before Peeks responds.

A report made in good faith does not breach any duty of confidentiality owed to the Player.

A suspicion that arises after a transaction is complete, including after the Account is closed, is reported in the same way. When new information gives grounds for suspicion, Peeks reviews the earlier activity on the Account and on the Accounts linked to it.

Peeks does not carry out a transaction that it knows or suspects to be connected with Money Laundering, Terrorist Financing or Proliferation Financing until the Compliance Officer has decided on it and, where Applicable AML Law gives the Financial Intelligence Unit time to object, until that time has passed. Where holding the transaction is impossible, or would itself alert the Player that a report is being considered, Peeks may carry it out, and reports it at once.

Where a Competent Authority asks in writing for an Account to be kept open, or for a transaction to go ahead, Peeks may do so, and applies Enhanced Due Diligence to the Account while the request stands.

Where Peeks has reported an Account more than once and the activity continues, Peeks ends the Relationship under section 21, unless a Competent Authority asks otherwise, and closes the Account without disclosing the reports.

Neither Peeks nor any Staff member may disclose to a Player or to any other person that an internal report or a report to the Financial Intelligence Unit has been, is being or may be made, or that an investigation is under way or contemplated, except as Applicable AML Law allows. This rule against tipping-off continues to apply after the Account is closed and after a Staff member leaves Peeks.

While a matter is under review, Peeks may continue to correspond with the Player and to ask for information, in terms that do not disclose a report or an investigation.

Within Peeks, information about reports and investigations is shared only with those who need it to perform their duties.

A Player's right of access to personal data does not extend to reports to the Financial Intelligence Unit or to information whose disclosure would amount to tipping-off.

Peeks keeps:

• the information and documents obtained under Customer Due Diligence and Enhanced Due Diligence, and the results of verification;
• risk ratings and the reasons for them;
• the results of Sanctions, PEP and adverse media screening, and the handling of each possible match;
• Network Check records;
• a record of every transaction, including Deposits, Withdrawals, Bets and their settlement, Tips and Vault movements, with the Accounts, amounts, dates and times concerned;
• for each Trade, the Steam account, the items, the prices, the history of its status and the Payment Partner's references;
• the Seeds and Round records described in clause 18.4;
• messages exchanged with Support;
• internal reports, reports to the Financial Intelligence Unit, requests from authorities and the decisions taken on them;
• the notes of each investigation, including the reasons for any decision not to report;
• each version of the Business Risk Assessment and of the risk appetite, with the data and analysis behind it;
• the Compliance Officer's reports to the Management Body and the decisions taken on them;
• each independent review report, with a record of how each weakness was corrected;
• the checks made on providers under clause 5.15 and on Staff under clauses 27.3 and 27.6, and their results; and
• records of Staff training and of reviews of this Policy.

Records are kept for as long as Applicable AML Law requires. Records are kept for longer while a Competent Authority asks, or an investigation or proceedings require it. They are then deleted or anonymized as the Privacy policy provides.

Records are kept in a form from which any transaction can be reconstructed and supplied promptly to a Competent Authority. Each change to a Balance is recorded as a journal of balanced entries that shows the resulting Balance. The database refuses an entry whose resulting Balance does not follow from the one before it, and the ledger, its journals and the audit log are append-only: the database rejects any attempt to change or delete an entry once it has been written.

When the retention period ends, personal data is dealt with as the Privacy policy provides.

Messages exchanged with Support and the record of every movement into and out of the Vault are kept in the same append-only form. A Player can download the recent history of the Account's Bets and transactions from the Account.

Where Peeks keeps copies of the ledger, the audit log and the records in clause 25.1 on systems apart from the live Service, access to them is limited to the roles that need it.

A downloaded history is a record of the Account and not a statement by Peeks. Peeks issues a signed statement or letter about a Player's Winnings, whether for a bank, a tax authority or anyone else, only after the Compliance Officer has reviewed the Account's Deposits, Tips, Bets and Withdrawals for the period it covers, and Peeks may refuse to issue one. A statement shows net results and never presents a Deposit or a Tip received as Winnings.

Peeks processes personal data under this Policy to comply with its legal obligations under Applicable AML Law, and uses that data for no other purpose except as the Privacy policy provides.

Names and country are stored encrypted, and date of birth, address, answers about Source of Funds and documents sent through the Site are sealed so that the Site cannot read them back. Once the Identity Partner is connected, identity documents will be handled through it, and its liveness check will compare the Player's face with the photograph on the identity document; that data is handled as clause 7.7 of the Identity verification policy provides. Staff can see a Player's email address, and the network prefix in a record of the Network Check, only through a permission granted to their role, and no staff screen shows Verification Level 1 details. Section 15 of the Privacy policy sets out the security measures that apply.

Peeks shares personal data under this Policy only with the following recipients, each only as far as it needs, and never sells it:

• the Financial Intelligence Unit, SUGEF and the other Competent Authorities;
• the Identity Partner and its screening provider, once engaged;
• any network intelligence provider it uses, which receives the network address under section 12, and Cloudflare;
• its Payment Partners;
• Steam, where Peeks reports Skins it believes to be stolen or a Steam account it believes to be compromised;
• a Studio or the Game Aggregator, where a Round of that Studio's game is under review;
• other gambling operators, where Applicable AML Law allows information to be shared to prevent fraud or Money Laundering; and
• the independent reviewer under clause 27.4, Peeks' auditors and its legal advisers, each of whom is bound to confidentiality.

Some rights a Player has under Law 8968 may be limited where exercising them would prejudice the prevention or detection of crime or would breach Applicable AML Law.

The Privacy policy explains how personal data is processed, where it is transferred and how a Player can exercise the rights that apply.

An Account can have only one live session. Logging in on another device ends the earlier session, and changing the password logs out every other device. Each displacement of a session is recorded, and repeated displacement between devices may be reviewed as a sign that more than one person is using the Account.

Staff are trained on this Policy before they take up duties that involve Players, payments, Skins or compliance, and at least once a year after that. Training covers Applicable AML Law, the personal liability a Staff member faces for failing to report or for tipping-off, the ways in which the Service could be misused, the indicators in section 34 with particular attention to Skins and Tips, Sanctions, internal reporting, tipping-off and data protection. Its content follows the role:

• Support Staff learn the indicators and how to escalate a concern;
• Staff who handle Trades and Withdrawals learn the controls on Trades, Reversals and prices;
• Staff who build or change the ledger, the Network Check or the monitoring learn what each control must achieve; and
• the members of the Management Body learn their duties under section 5.

Each training ends with a test, and a Staff member who does not pass repeats it. Peeks keeps records of the training given, its content and its results. The Compliance Officer receives specialized training suited to the role.

Before engaging a person in a role covered by clause 27.1, Peeks verifies the person's identity, checks references and screens the person against Sanctions lists and, where the law allows, against criminal records.

The application of this Policy is reviewed independently, by a qualified person who takes no part in its day-to-day operation. The review covers at least:

• a sample of Customer Due Diligence and Enhanced Due Diligence files;
• whether alerts were reviewed, and reports filed, in time;
• the Business Risk Assessment and the ratings given to Accounts;
• Staff access to Player data and to the audit log, including every money command issued without a second approval under clause 5.8;
• the reconciliation of Trades under clause 14.10; and
• the training records.

The findings go to the Management Body, which ensures that weaknesses are corrected and records how.

Each Staff member confirms in writing, on joining and after each change to this Policy, that he or she has read it. A Staff member whose training is overdue loses access to Player data and money tools until it is complete.

Peeks screens Staff against the Sanctions lists in clause 11.2 whenever a list is updated and asks each Staff member to confirm every year the connections that clause 5.10 requires them to declare. The Compliance Officer samples Staff actions in the audit log and looks into any action that has no recorded reason.

Spending out of line with a Player's means can be a sign of gambling harm as well as of Money Laundering. Where a review under this Policy shows signs of harm, the matter is also dealt with under the Responsible gambling policy.

Deposit limits, Loss limits, the Daily stake limit, the Time limit, the Play break and Self-exclusion are available on the Responsible play page.

A Play break or Self-exclusion does not suspend the measures in this Policy. A Player on a Play break or in Self-exclusion may still be asked for information, and may withdraw subject to the checks in section 20.

You must:

• give Peeks true, complete and current information, and tell Peeks promptly when it changes;
• use an email address that is your own and that only you can read;
• use only your own money, your own Skins and your own Digital Currency, from lawful sources;
• deposit only from, and withdraw only to, your own Linked Steam Account and wallets or accounts that you own and control, by a method and in a Coin that clause 9.31 of the Terms allows;
• provide the information and documents Peeks asks for within the time it sets, even where you disagree with the request; you may ask for a review under section 30, but the request stands while the review runs;
• tell Support before your first Deposit if you hold a prominent public function or are a family member or close associate of a person who does, tell Peeks promptly of any change, as clause 10.4 requires, and tell Peeks at once if you become a Sanctioned Person;
• keep your Account secure, including with two-step login, and keep your login details to yourself;
• tell Peeks at once if you think someone else has got into your Account, your email or your Steam account, or if your identity document is lost or stolen; and
• comply with the laws of the country you are in, including those on the origin of funds and on taxes.

You must not:

• open or use more than one Account, or use another person's Account;
• let any other person use your Account or your Steam account, or act on another person's behalf;
• sell, buy, rent, lend or share an Account or a Steam account;
• use a Masking Tool, such as a VPN, a proxy, Tor or a hosting network, to hide your identity or location;
• use the Service from a Restricted Territory;
• use Tips, the Vault, Bets or Trades to move value for any purpose other than your own play;
• divide transactions to avoid a threshold or a check;
• interfere with, test or try to get round any check in this Policy, including with images or video made or altered by software, a camera feed that is not live, or a device or browser set up to hide what it is;
• open another Account, or reverse a Trade, to get round a check or a held Withdrawal;
• give a false explanation of a transaction; or
• provide false or altered documents, or documents belonging to another person.

A breach of this section entitles Peeks to take any of the steps in section 21.

When a Player reports that an Account or a Steam account may be compromised, Peeks may pause Withdrawals, Tips and changes of Linked Steam Account or Trade URL while it checks. The report is not itself a breach.

A Player may ask Peeks to review a restriction, a refused transaction or a closure by contacting Support or by making a complaint under the Complaints policy.

A review is carried out by a person who did not take the original decision, with the involvement of the Compliance Officer where the decision was taken for compliance reasons. Peeks gives the outcome in writing, but may be unable to give its reasons where section 24 prevents it.

A block made by the Network Check is reviewed by a member of Staff at the Player's request.

Peeks acknowledges a request for review, and gives its outcome, within the times that the Complaints policy sets for a Formal Complaint.

A restriction stays in place while a review runs. Each decision rests on the information Peeks holds when it is taken, and Peeks reconsiders it where the Player later provides new information that Peeks can verify.

A Player may ask for any outcome reached by automated means under this Policy to be reviewed by a member of Staff.

A Player who is not satisfied with the outcome may take the matter further under the Complaints policy. At every stage, section 24 and clause 19.11 limit what Peeks can disclose.

Peeks asks for information and documents under this Policy only through the Site, from support@peeks.gg or, once the Identity Partner is connected, through its capture page reached from the Site. Peeks does not ask for documents through Discord, social media or any other channel.

Staff never ask for a Player's password, two-step codes, recovery codes, Steam Guard codes or Steam Web API key. A Player who receives such a request must not answer it and should report it to Support.

Peeks reviews this Policy at least once a year and whenever Applicable AML Law, the risks to the Service or the Service itself changes.

Each version of this Policy shows its effective date at the top of this page and takes effect on that date. Peeks publishes a short summary of each material change with the new version, keeps every earlier version and records who approved each one.

The Management Body approves each material change. A correction, or a change that only follows a change in the law or in the Service, may be approved by the Compliance Officer and reported to the Management Body.

Where a change reduces a Player's rights or adds to a Player's obligations in a material way, Peeks gives notice as clause 1.7 of the Terms provides. A change needed to comply with Applicable AML Law, or to deal with Money Laundering, fraud or a security threat, may take effect at once. Using the Service after a change takes effect is acceptance of it.

A review, restriction or request already under way when a new version takes effect continues under the version in force when it began, unless Applicable AML Law requires otherwise or the new version is more favorable to the Player.

Questions about this Policy may be sent through Support or to support@peeks.gg, marked for the attention of the Compliance Officer.

The indicators below are among those that lead Peeks to review an Account. An indicator is a reason for a closer look, not proof of wrongdoing, and Peeks considers each one in the light of everything it knows about the Player.

Identity and the Account:

• the Player is reluctant to provide information, provides it piece by piece or provides details that cannot be verified;
• documents appear altered, are inconsistent with one another or with the Account, or belong to another person;
• the same identity details, address, email pattern, device, network, Steam account or Trade URL appear on more than one Account, or several Accounts follow the same pattern of play;
• an attempt to link a Steam account already linked to another Account, or to save a Trade URL that belongs to a different Steam account;
• the Player's age, occupation or circumstances are inconsistent with the amounts involved;
• the Account is opened, used briefly and abandoned with a Balance, or the Player appears to be acting on someone else's instructions;
• an Account that has lain dormant under the Terms returns with Deposits, Tips or Withdrawals far above its earlier activity;
• an attempt to get round a Play break, Self-exclusion or a limit, including by opening another Account or by having another person play;
• a request for a statement of Winnings that the Account's play does not support, or for a statement addressed to someone other than the Player; and
• the Player asks about thresholds, about how to avoid checks, about moving value to another Account or another person, or about what Peeks reports to the authorities.

Network and location:

• repeated Network Check findings, including repeated attempts after a block;
• a device time zone that does not match the network or the declared country;
• logins from several countries within a short period, or from a Restricted Territory;
• recovery of the Account without its authenticator app or recovery codes, followed soon after by a Withdrawal, a Tip or a change of Linked Steam Account or Trade URL; and
• frequent changes of email address, password or Steam account, particularly shortly before a Withdrawal.

Deposits of Skins:

• Skins deposited soon after they were acquired, particularly from a Steam account with little history;
• Skins of high value deposited by a new Account, or Deposits out of line with the Account's history;
• Reversals after Deposits land, or Deposits from a Steam account linked shortly before;
• the same or similar items deposited by several Accounts in a pattern;
• items deposited at a price far above their recent sales, or items traded so rarely that their price is easy to move, in particular where the same items return again and again, arrive from several Accounts or are followed by a Withdrawal of items that sell easily;
• many small Deposits made close together where fewer would serve; and
• Skins reported as stolen, or obtained from a Steam account reported as compromised.

Withdrawals:

• a Withdrawal soon after a Deposit, with little or no play in between;
• Withdrawals divided into several Trades, or repeated Withdrawals just below a threshold;
• repeated declines, cancellations or Reversals of Withdrawals;
• a Withdrawal requested soon after a change to the Linked Steam Account or the Trade URL; and
• a request to pay a Withdrawal to another person, or by a method or in a Coin not used for the Account's Deposits.

Play:

• Bets at little risk on Games with a low house edge that turn Deposits over without apparent interest in the outcome;
• Bets on opposing outcomes placed by Accounts acting together;
• stakes that change sharply without explanation;
• large losses accepted again and again without apparent concern, out of line with what Peeks knows of the Player's means; and
• automated or scripted play.

Tips and the Vault:

• value tipped soon after it is deposited, or withdrawn soon after it is received as a Tip;
• many Accounts tipping one Account, or one Account tipping many;
• Tips that pass in a circle and return to their source;
• Tips between Accounts that share details or are controlled together;
• Tips that appear to settle a sale, a debt or a wager made elsewhere; and
• amounts moved into and out of the Vault without play, combined with Deposits and Withdrawals.

Other conduct:

• adverse media linking the Player to crime;
• a link between the Player and a Sanctioned Person;
• an offer to pay outside the Cashier, Digital Currency that comes through mixers, tumblers or privacy coins or from addresses linked to darknet markets, or references to darknet markets; and
• an offer of a gift or payment to Staff, or pressure on Staff to skip a check.

Peeks rates each Account on the factors in this section. A single factor may be decisive: a confirmed Sanctions match makes the Relationship unacceptable, and PEP status makes it high risk.

Customer factors: PEP status; adverse media; an occupation or source of income in a sector of higher risk, such as businesses that handle large amounts of cash, dealers in goods of high value or providers of virtual asset services; a refusal or delay in providing information; a history of more than one Account; and a previous closure or restriction.

Geographic factors: the Player's country of residence and any nationality that Peeks holds for the Player; whether a country concerned is identified by FATF as under increased monitoring or is rated as high risk in the Business Risk Assessment; the country recorded by the Network Check; and any mismatch between those countries.

Product and payment factors: the value of Deposits and Withdrawals by each method, including Skins and Digital Currency; the share of Deposits made in Counter-Strike 2 Skins subject to the Trade hold; Reversals and declines; the volume of Tips sent and received; the use of the Vault; the share of play on Games with a low house edge; and the share of Deposits made up of items that rarely trade.

Channel and technology factors: Network Check findings, including time-zone differences; the number of changes of Linked Steam Account and Trade URL; and the number of changes of email address and password.

Transaction factors: the amounts, frequency and speed of Deposits and Withdrawals; Linked Transactions; Withdrawals that follow Deposits with little play; and activity out of line with the Source of Funds or with the profile Peeks holds.

Identity: a valid passport, national identity card (including a residence document issued to a foreign resident) or driving license issued by a government and bearing the Player's photograph, full name, date of birth and expiry date, and a liveness check carried out through the Identity Partner.

Address: a bill for electricity, water, gas, a landline telephone or home internet, a statement from a bank or another regulated financial institution, a letter or statement from a government authority such as a tax or social security office, a home insurance document, a tenancy agreement, or any other document named in Peeks' request. Each must show the Player's full name and residential address, the name of its issuer and its date of issue, and each other than a tenancy agreement must be dated within the last 3 months.

Standards: each document must be complete, with all its edges visible, in color, legible, unaltered and in date, and must match the details on the Account. An identity document must be captured from the original, and Peeks does not accept a photocopy, a printout, a screenshot or a picture of a screen of one, other than a certified copy that Peeks asks for under clause 36.6. A proof of address may be a statement downloaded from its issuer as a PDF, but not a screenshot of a web page or an app. Peeks may ask for a translation, made by an official translator, of a document that is not in English or Spanish.

Steam account: screenshots or exports taken from within the Steam account that show its name, its Steam ID and its purchase, market and trade history.

Source of Funds and Source of Wealth: the evidence listed in clause 13.3.

Where Peeks doubts a document, it may ask for the original, for a certified copy or for a different document, and may verify the document with its issuer.