FootyPass Legal
Anti-Money Laundering (AML) Policy
This Policy explains the measures FootyPass may use to reduce the risk of money laundering, terrorist financing, fraud, and other financial crime through its ticket marketplace.
1. Purpose and Scope
FootyPass seeks to prevent its accounts, ticket marketplace, payments, and seller payout features from being misused for money laundering, terrorist financing, fraud, or other financial crime.
1.1 Purpose of This Policy
This Policy describes the financial-crime controls FootyPass may apply when operating its marketplace and related services.
1.2 Who This Policy Applies To
This Policy applies to buyers, sellers, account holders, and other users whose activity may create financial-crime or marketplace-integrity risks.
1.3 Services Covered
Relevant controls may apply to accounts, ticket listings, purchases, payments, seller earnings, wallets, payouts, refunds, and other marketplace activity.
1.4 Applicable Requirements
FootyPass will comply with financial-crime obligations that apply to its activities and jurisdiction. This Policy does not by itself represent that FootyPass is a regulated financial institution.
2. Risk-Based Approach and Prohibited Activity
FootyPass may apply proportionate controls according to the nature and level of financial-crime risk associated with an account, transaction, listing, or payout.
2.1 Risk Assessment
FootyPass may consider transaction patterns, account behaviour, payment activity, seller history, geographic indicators, and other relevant information when assessing risk.
2.2 Prohibited Use
Users must not use FootyPass to conceal, transfer, convert, receive, or otherwise deal with proceeds of unlawful activity.
2.3 Third-Party Transactions
Users must not improperly use another person, account, payment method, or payout destination to conceal the identity or source of funds associated with a transaction.
2.4 Structuring and Evasion
Users must not deliberately divide, disguise, manipulate, or otherwise arrange activity for the purpose of avoiding reasonable financial-crime, identity, payment, or security controls.
2.5 Higher-Risk Activity
FootyPass may apply additional checks or restrictions where activity presents an elevated risk of fraud, money laundering, terrorist financing, sanctions evasion, or other financial crime.
3. Identity and Seller Verification
FootyPass may request information or documentation to verify users, sellers, payout recipients, or marketplace activity where reasonably necessary for security, fraud prevention, or financial-crime controls.
3.1 Account Verification
Users may be required to verify account information before accessing particular FootyPass features or completing certain transactions.
3.2 Seller Verification
FootyPass may require sellers to provide additional identifying information before allowing listings, releasing earnings, or processing payouts.
3.3 Supporting Documents
Where appropriate, FootyPass may request identity documents, ticket-purchase evidence, proof of entitlement, payout information, or other reasonable supporting material.
3.4 Verification Providers
FootyPass may use appropriate third-party providers to assist with identity, payment, security, or fraud checks.
3.5 Accuracy of Information
Users must provide accurate information and must not submit forged, altered, misleading, stolen, or otherwise fraudulent verification material.
3.6 Additional Checks
FootyPass may request additional verification where information cannot be confirmed, circumstances change, or elevated risk indicators are identified.
4. Transaction and Payout Monitoring
FootyPass may monitor marketplace and financial activity to identify unusual behaviour, protect users, and determine whether additional review is appropriate.
4.1 Transaction Patterns
FootyPass may review patterns involving purchases, sales, refunds, cancellations, payment attempts, seller earnings, and payouts.
4.2 Unusual Activity
Activity that materially differs from expected marketplace behaviour may be subject to additional review.
4.3 Payment Information
Relevant payment information and risk indicators may be considered when detecting potentially unauthorised, fraudulent, or suspicious transactions.
4.4 Seller Wallet Activity
Pending earnings, adjustments, payout requests, and other seller-wallet activity may be reviewed where financial-crime or fraud concerns arise.
4.5 Payout Holds
FootyPass may delay or restrict a payout where reasonably necessary to investigate suspected fraud, account compromise, a transaction dispute, or other serious risk, subject to applicable law and FootyPass policies.
4.6 Ongoing Monitoring
Where justified by risk, relevant account or transaction activity may remain subject to continued monitoring or additional verification.
5. Suspicious Activity and Enforcement
Where FootyPass identifies activity that may involve financial crime, fraud, serious marketplace abuse, or unlawful conduct, appropriate protective or investigative action may be taken.
5.1 Investigation
FootyPass may review account information, transaction records, communications, ticket evidence, payment information, and other relevant records when investigating suspicious activity.
5.2 Additional Information
A user may be asked to provide further information or documentation where reasonably necessary to understand or verify suspicious activity.
5.3 Transaction Restrictions
FootyPass may pause, decline, cancel, or restrict a transaction where permitted and reasonably necessary to manage serious financial-crime or fraud risk.
5.4 Account Restrictions
Accounts may be temporarily restricted or suspended while serious suspicious activity is investigated.
5.5 Withholding Payouts
Seller funds may remain pending or subject to an appropriate hold where necessary to investigate a qualifying risk, dispute, legal requirement, or suspected fraud.
5.6 Cooperation With Authorities
FootyPass may preserve or disclose relevant information to competent authorities, law-enforcement bodies, payment providers, or other authorised parties where required or permitted by applicable law.
5.7 No Guarantee of Disclosure
FootyPass may be unable to disclose particular details concerning a financial-crime investigation, restriction, report, or legal request where disclosure would be unlawful, compromise security, or prejudice an investigation.
6. Records, Information and Privacy
FootyPass may maintain information relating to verification, transactions, investigations, restrictions, and other financial-crime controls where reasonably necessary and lawful.
6.1 Verification Records
Information used to verify an account, seller, transaction, or payout may be retained where reasonably necessary for security, fraud prevention, dispute handling, or applicable obligations.
6.2 Transaction Records
FootyPass may retain relevant records of purchases, sales, payments, refunds, seller earnings, wallet activity, and payouts.
6.3 Investigation Records
Records concerning suspicious activity, fraud investigations, account restrictions, and related decisions may be retained where appropriate.
6.4 Retention Periods
Information will be retained for periods reasonably necessary for its purpose and any applicable legal, accounting, security, or regulatory requirements.
6.5 Privacy and Security
Personal information processed for financial-crime purposes will also be handled in accordance with the FootyPass Privacy Policy and applicable data protection requirements.
7. Policy Updates and Contact
FootyPass may update this AML Policy as marketplace risks, platform features, payment arrangements, or applicable legal requirements develop.
7.1 Policy Changes
FootyPass may revise this Policy to reflect changes to financial-crime risks, marketplace controls, technology, payment services, or applicable requirements.
7.2 Material Updates
Where appropriate, significant changes may be communicated through FootyPass or another suitable method.
7.3 Reporting Concerns
Users who become aware of suspected fraud, misuse of FootyPass, suspicious ticket activity, or other potentially unlawful conduct may contact FootyPass through the available support or reporting channels.
7.4 Questions About This Policy
Questions concerning this AML Policy may be submitted using the contact methods provided through FootyPass.