1. Purpose of the Policy
This AML/KYC Policy describes how Motiw8 prevents:
- Money laundering
- Terrorist financing
- Fraudulent financial activity
- Abuse of the platform's payout system
This Policy applies to all users globally.
Motiw8 UAB is not a financial institution, but because the platform facilitates:
- holding stakes
- distributing prize payouts
- maintaining user balances
…it must comply with EU AMLD6, national Lithuanian AML rules, and FATF recommendations.
2. Regulatory Framework
This Policy is based on:
- EU Anti-Money Laundering Directive 6 (AMLD6)
- Lithuanian Law on Prevention of Money Laundering & Terrorist Financing
- FATF Recommendations
- PSD2 & E-Money Regulations (Stripe handles the regulated functions)
- Stripe Connect Standard AML Framework
- Apple/Google in-app purchase rules
3. Scope
This Policy covers:
- User identity verification (KYC)
- Monitoring of financial activity
- Fraud detection
- Payout controls
- Suspicious activity reporting
- Sanctions screening
4. KYC Requirements (Know Your Customer)
4.1 Mandatory KYC Triggers
Users must complete identity verification (via Stripe Identity) if ANY of the following occurs:
(a) Payout Threshold
User wins or withdraws €600+ / $600+ in a calendar year
(aligns with 1099-K thresholds)
(b) Suspicious Activity
Any behavior flagged by anti-fraud algorithms:
- repeated large wins
- abnormal patterns
- mismatched bank details
- location anomalies
- video/face evidence inconsistencies
(c) Large Stake Challenges
If user participates in high-stake competitions (€50+ per stake).
(d) Stripe Requirements
If Stripe detects a compliance trigger (document expiry, sanctions match, name inconsistencies).
4.2 KYC Methods
Identity verification is performed exclusively by Stripe Identity:
Collected documents may include:
- Passport
- National ID card
- Driver's license
- Selfie/liveness check
Motiw8 does not store ID photos.
Stripe stores them per its own regulatory obligations.
5. AML Transaction Monitoring
The following activities may trigger internal review:
High-Risk Behaviors:
- Multiple accounts controlled by the same user
- Funding stakes with stolen cards
- Rapid join → leave → join loops
- Winning patterns inconsistent with physical ability
- Uploading manipulated evidence
- VPN-based location anomalies
- Unusual payout requests
- Rapid withdrawals after large wins
- Attempts to bypass liveness or face match requirements
Moderate-Risk Behaviors:
- Multiple refund requests
- Disputes involving evidence manipulation
- Low-quality or inconsistent timestamp data
- Sudden weight fluctuations (fraud signals)
6. Sanctions Screening
Stripe automatically screens:
- OFAC
- EU Sanctions List
- UN Sanctions List
- National PEP Lists
Users matched on sanctions lists are blocked.
7. Record Keeping
Per EU law:
- AML/KYC data (Stripe) retained 7 years
- Transaction logs retained 7 years
- Suspicious activity records retained 7 years
Motiw8 does not store ID photos locally.
8. Suspicious Activity Reporting
If required by law, Motiw8 may:
- block payouts
- freeze stakes
- suspend account
- forward findings to competent authorities
Motiw8 is not required to notify the user if reporting is legally prohibited.
9. User Responsibilities
Users must:
- Provide accurate identity information
- Use their own payment methods
- Withdraw funds only to accounts they control
- Not engage in cheating/fraud
- Complete KYC when requested
10. Penalties
Motiw8 may impose:
- account suspension
- permanent bans
- stake forfeiture
- blocked payouts
- report to appropriate authorities