1. Introduction
Cults SAS (Β« Cults3D Β»), as a marketplace platform specializing in the sale of 3D files, is committed to complying with the legal and regulatory requirements related to anti-money laundering (AML) and counter-terrorism financing (CTF), as defined in the 2nd Payment Services Directive (PSD2) and the directives of the European Union (EU). This document aims to present the measures implemented by Cults SAS to ensure its compliance with these regulations, particularly concerning identity verification (KYC) procedures and the screening of sub-merchants.
This policy is in compliance with the Payment Services Directive 2 (PSD2) and the 5th Anti-Money Laundering Directive (AMLD5) of the European Union.
2. Context and Applicability of PSD2
The Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market (hereinafter "PSD2") imposes compliance obligations on payment service providers (PSPs) and, in certain cases, on marketplace platforms such as Cults3D, when they are involved in processing payments or facilitating financial transactions between buyers and sellers.
Cults3D acts as a transparent intermediary by facilitating transactions between sellers (designers) and buyers of 3D files. In this capacity, collaboration with payment service providers (Stripe, PayPal, and Payoneer) ensures the processing of transactions. PSD2 impacts activities in of transparency and security of payments, verification of sellers, and prevention of fraud and money laundering.
PSD2 aims to strengthen the security of electronic payments, protect consumers, and encourage innovation and competition. It introduces strict requirements for payment security, including strong customer authentication (SCA) and secure communication.
3. Objective
The objectives of this policy are:
- To identify and the identity of platform s.
- To monitor transactions to detect any suspicious activity.
- To report potentially illegal activities to the competent authorities.
- To comply with international sanctions and anti-money laundering laws.
4. Verification of s (KYC - Know Your Customer)
4.1 Collection of Information
Cults3D sub-merchants must provide complete information during their registration. This information includes, but is not limited to:
For individuals:
- Full name
- Date of birth
- Address
- Country of residence
- Email address
- Phone number
- ID document
- Tax registration number
For companies:
- Company name
- Company address
- Identity of the director (full name, date of birth)
- Tax registration number
- VAT number
- ID document
To receive their payments, sub-merchants are required to synchronize their payment , such as Payoneer, Stripe, bank , or PayPal, via the platform. They must provide these service providers with complete and accurate information so that their payment s are valid and duly verified.
4.2 Identity Verification
The submitted information is verified using identity verification automation solutions provided by specialized third parties (Stripe Identity), and through a manual process for complex cases. Cults3D may request additional documents if there is any doubt about a 's identity. Data relating to the identity of customers and sellers, as well as operations, are retained for a period in compliance with regulations.
4.3 Control of Politically Exposed Persons (PEP)
Regular checks are carried out to identify politically exposed persons (PEPs), and enhanced due diligence procedures are applied to these s.
4.4 Strong Authentication
Two-factor strong authentication (2FA) is available to all platform s and is required for all sub-merchants to protect them, in accordance with security recommendations (ANSSI, CNIL).
5. Transaction Monitoring
5.1 Transaction Filtering
All payments made on Cults3D are monitored via the Stripe Radar solution and fraud detection tools to detect unusual or suspicious behavior (high number of declined payment attempts, high-risk payments, etc.). Fraud detection tools are used to report suspicious transactions. SCA verification is systematic for each seller, and all transactions go through 3DS verification.
5.2 Alert System
An automated alert system signals:
- Transactions detected as potentially fraudulent.
- s exhibiting atypical or suspicious behavior.
- Reports made by visitors regarding products or s that do not comply with the platform's and conditions.
An automatic moderation system based on specific keywords is also in place. When an alert is triggered, a manual evaluation is conducted to determine if the activity should be reported as suspicious and result in a block.
5.3 Reporting of Suspicious Activities (SAR - Suspicious Activity Report)
In case of suspicion of money laundering or illegal activities, a suspicious activity report (SAR) is submitted to the competent authorities, in accordance with regulations.
6. Compliance with International Sanctions
Cults3D ensures that its s and transactions are not linked to countries, entities, or individuals under international sanctions. These verifications are carried out via sanctions databases, such as the United Nations list or that of the European Union.
Transactions, bank cards, and Stripe s linked to sanctioned countries or persons are refused, in accordance with regulations. In particular, transactions from the following countries are not accepted:
- Cuba
- Iran
- Syria
- North Korea
- Crimea (Autonomous Region)
7. Enhanced Due Diligence Measures
Enhanced due diligence measures are implemented in certain cases, for example when:
- Transactions originate from high-risk countries.
- The is a politically exposed person (PEP).
- Inconsistencies are found in the information provided by a .
These measures may include requesting additional information and conducting in-depth verifications before allowing the use of services.
8. Employee Training
All employees involved in the management of transactions or regulatory compliance receive regular training on AML and KYC policies. This training covers the latest regulations, as well as the detection and reporting of suspicious activities.
9. Updates and Reviews
This policy is reviewed and updated every 12 months, or more frequently if necessary, to ensure its effectiveness and compliance with new regulations regarding anti-money laundering and counter-terrorism financing.
cults3d.sitegames.net is fully aware of the issues related to the fight against money laundering and is committed to complying with all legal and regulatory obligations that apply to it.
- Date of last update: 1st August 2024
- Compliance Officer: Sunny Ripert
- Position: CTO