Comprehensive Know Your Customer/Anti-Money Laundering Policy for Pryzr, Inc.

Last Updated: September 17th, 2024

I. Introduction

Pryzr, Inc. ("Pryzr" or the "Company") is committed to maintaining the highest standards of integrity and transparency in its operations. This policy outlines the Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures, as well as the Sweepstakes Rules, to be followed by Pryzr in its sweepstakes promotions in non-excluded states. Pryzr is dedicated to complying with all applicable federal and state laws and regulations, including but not limited to the Bank Secrecy Act (BSA), the USA PATRIOT Act, and various state Sweepstakes and Lottery Promotion Laws. “Excluded Territory” means the States of Washington, Montana, Maryland, Pennsylvania, New Jersey, Connecticut, West Virginia, Louisiana, Rhode Island, Delaware, Nevada, Michigan, and Idaho, as well as any U.S. territory or possession, and any other jurisdiction outside of the United States.

II. Know Your Customer & Anti-Money Laundering Policy

A. Customer Identification Program (CIP)

1. Collection of Information: Pryzr will collect the following information from each sweepstakes participant at the time of entry or prize claim, as applicable:

  • Full legal name
  • Date of birth
  • Residential address
  • Social Security Number (or other government-issued identification number)
  • Email address
  • Phone number

2. Verification of Information: Pryzr will employ a multi-layered approach to verify the participant's identity, utilizing reliable, independent sources, such as:

  • Government-issued identification documents (e.g., driver's license, passport)
  • Credit reports
  • Public databases
  • Third-party identity verification services

3. Recordkeeping: Pryzr will maintain secure records of all collected and verified information for a minimum of five years, in accordance with applicable regulations.

B. Customer Due Diligence (CDD)

1. Risk Assessment: Pryzr will conduct a risk-based approach to customer due diligence, assessing each participant's risk profile based on factors such as:

  • Geographic location
  • Transaction history (if applicable)
  • Source of funds (if applicable)
  • Politically Exposed Person (PEP) status
  • Adverse media or negative news

2. Enhanced Due Diligence (EDD): Pryzr will conduct EDD for participants deemed to be high-risk, which may include:

  • Obtaining additional information about the participant's identity, source of wealth, and business activities.
  • Scrutinizing the participant's transactions more closely.
  • Requiring additional documentation to verify the source of funds.

C. Suspicious Activity Reporting (SAR)

1. Identification of Suspicious Activity: Pryzr has implemented a robust system for monitoring and identifying suspicious activity, which includes:

  • Large or unusual transactions
  • Attempts to structure transactions to avoid reporting requirements
  • Transactions involving high-risk jurisdictions or sanctioned individuals
  • Any activity that appears to have no apparent business or lawful purpose

2. Reporting: Pryzr will promptly file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN) for any identified suspicious activity, in accordance with applicable laws and regulations.

D. Anti-Money Laundering Compliance Officer

1. Designation: Pryzr will retain the services of a qualified third-party Anti-Money Laundering Compliance Officer responsible for overseeing and managing the Company's AML program.

2. Responsibilities: The AML Compliance Officer's responsibilities will include:

  • Developing, implementing, and maintaining Pryzr's AML policies and procedures.
  • Conducting ongoing training for employees on AML compliance.
  • Monitoring transactions and customer activity for suspicious patterns.
  • Ensuring timely filing of SARs.
  • Staying abreast of regulatory changes and industry best practices.

E. Sanctions Screening

1. OFAC Compliance: Pryzr will screen all participants against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list and other relevant sanctions lists to ensure compliance with U.S. economic sanctions programs.

2. Ongoing Monitoring: Pryzr will implement ongoing monitoring of customer transactions and activities to identify any potential matches to sanctions lists.

III. Sweepstakes Rules

A. Eligibility:

  • Participants must be at least 18 years old to enter.
  • Participants must be legal residents of a US State with the exception of the “Excluded States” as defined in the introduction of this document.
  • Employees of Pryzr, its affiliates, subsidiaries, advertising and promotion agencies, and their immediate family members are not eligible to participate.

B. Entry:

  • No purchase is necessary to enter or win. A purchase will not increase your chances of winning.
  • Method of Entry: Participants may enter by [specify method of entry, e.g., online registration, mail-in entry, social media contest].
  • Entry Limit: There are no entry limits.

C. Prizes:

  • Prize Pool: The sweepstakes will offer an exciting array of prizes, including Pryzr-branded merchandise and cash prizes, which will be outlined in the official sweepstakes rules.
  • State Law Compliance: Pryzr will comply with all state laws governing sweepstakes and prize promotions.
  • Odds of Winning: The odds depend on the total number of eligible entries received.
  • Prize Acceptance: All prizes are awarded "as is" and are non-transferable unless Pryzr permits.
  • Unclaimed Prizes: Prizes must be claimed within the specified timeframe; unclaimed prizes may be forfeited.

D. Winner Notification:

  • Potential winners will be notified in real time via the website.
  • Verification: Winners may need to complete an affidavit of eligibility and a liability/publicity release to claim their prize.

E. General:

  • Taxes: Winners are responsible for all taxes associated with the prize.
  • Publicity: By entering, participants consent to Pryzr using their name and likeness for promotional purposes.
  • Disputes: Sweepstakes-related disputes will be governed by Virginia law.
  • Right to Modify: Pryzr reserves the right to modify or terminate the sweepstakes at any time.

IV. Conclusion

This policy is subject to change at any time. By participating in any sweepstakes, participants agree to be bound by these rules and Pryzr's Know Your Customer/Anti-Money Laundering policy.