Policy Preventing the Use of FlashSkins.gg for Criminal Purposes
Last updated: 5/20/2026
General Risk Related to the Services Provided and Virtual Assets
The provision of services related to the trading of virtual items inherently carries the risk that these items may be used for illegal activities, such as money laundering, terrorist financing, fraud, fiscal crimes, or other prohibited acts.
Items in virtual form are easy to store and can be transferred relatively quickly, which increases the attractiveness of using such assets for criminal purposes.
The ease of transferring items between users, as well as between various types of services, also facilitates the transfer of value associated with virtual assets.
An important role is also played by the possibility of monetizing virtual items by exchanging them for traditional funds, cryptocurrencies, other tangible or intangible goods, which may attract the interest of persons holding proceeds of crime, especially economic crimes.
The lack of unambiguous legal regulations concerning the trading of virtual items results in a non-uniform approach among entities supporting such trading to activities related to preventing the use of such assets for criminal purposes. Due to the lack of uniform standards, the risk of illegal practices also affects services that have implemented policies regarding the prevention of using their services for criminal purposes.
The widespread availability of websites related to the trading of virtual items enables anyone to conduct transactions, sometimes without any restrictions related to establishing the identity of the user or the source of the assets involved in the transactions.
The trading of virtual assets has no territorial limitations; these items can be sold to various persons from different locations without the need for physical transport, storage, or governmental oversight.
The above has a direct impact on the general risk of exposure of services related to the trading of virtual assets to use in criminal activities, in particular related to money laundering, due to the possibility of transferring funds from uncertain sources, unless this risk is appropriately mitigated through the implementation of proper practices and internal regulations, which is the purpose of introducing these solutions.
Actions Taken in Connection with Preventing the Use of FlashSkins.gg for Criminal Purposes
The Service's policy is aimed at combating unlawful activities, in particular at preventing money laundering, terrorist financing, fraud, and other activities contrary to the law; therefore, the Service provider has developed mechanisms enabling the monitoring of activity, identification of irregularities, and taking appropriate measures against suspicious operations.
In view of the above, in the course of establishing a relationship with the user and during the ongoing cooperation, the Service provider may require the user to provide information, data, and documents necessary to:
identify the user's data, which includes establishing, among other things, first name, last name, identification number, citizenship, date and place of birth, and residential address;
identify persons who actually benefit from the services, if the user acts on behalf of third parties or uses funds belonging to other entities. Verification of the user's persons actually benefiting from activity within the Service is also possible;
verify the identity of the user, consisting of confirming the accuracy of the provided identification data;
establish the user's activity within the Service, including establishing the value of current or projected turnover of virtual items, typical behavior and transfer of asset values by the user, and the typical model of using the Service;
analyze the user's activity for atypical actions, including actions inconsistent with the established user profile or user activity from the perspective of the rationality of their behavior (e.g., whether the user deliberately enters into transactions that are economically unfavorable to them), analysis of the user's assets in relation to their economic situation;
request documents confirming the source of funds engaged in the user's activity in the Service, including for the purposes of analyzing user behavior, where there is a reasonable suspicion of illegal activity;
check the presence of users on sanctions lists and identify persons with PEP status or associated with PEPs;
update data and documents, and in the case of a user with a recognized elevated risk, updates are carried out more frequently, at least once a year.
Information, data, and documents provided by the user are subject to protection in a manner ensuring their security against loss or unauthorized access, in accordance with applicable laws and implemented internal policies and procedures.
To perform the above activities, the Service provider designates appropriate persons with access rights to the personal data of Service users. To acquire, collect, process, and store user data, the Service provider may use both its own resources and the software of the Sumsub service (https://sumsub.com/).
The Service provider is authorized to use information and data for analyses aimed at determining whether the user's activity may be associated with criminal activity.
Premises of Elevated Risk of Criminal Activity and Actions Taken by the Service Provider
When providing services related to the trading of virtual items, the Service provider takes into account users' behavior, their transactional activity, and the nature of the activities performed to analyze whether the premises of elevated risk of using the Service for criminal purposes are met.
The premises that may indicate an elevated risk of using the Service for criminal purposes include mainly atypical or economically unjustified patterns of user activity, frequent or significant transfers of virtual items between associated accounts, conducting transactions of significant value in a short period of time, as well as other behaviors deviating from the standard manner of using the Service.
With respect to the premises of elevated risk of using the Service for criminal purposes, the following situations should be distinguished in particular:
using the services or the Service on behalf of third parties and using third-party financing;
concealing identity or using outdated, false, or someone else's documents;
exploiting technical errors of the Service;
using payment methods belonging to other persons (e.g., using a debit or credit card, or a payment account of a third party);
creating multiple accounts within the Service without a justified reason;
violating the terms of service, policies, and procedures concerning the operation of the Service;
introducing into the Service asset values that do not have a legal source or are not reflected in the user's income;
immediately removing virtual items after receiving them for the purpose of converting and transferring value, which may indicate that the Service is being used as a tool for converting and transferring asset values;
using virtual items as a tool for storing or transferring value derived from crimes (the trading of virtual items within the Service is for entertainment purposes and is not intended to create alternative methods of storing and transferring value);
instructing the withdrawal of funds to accounts, bank accounts, or wallets belonging to third parties.
The user is obliged to refrain from making deposits from accounts, bank accounts, or wallets that do not belong to them, as well as from making withdrawals to accounts, bank accounts, or wallets belonging to other persons or over which third parties have control.
In the event of a reasonable suspicion or finding that the user's actions fall within the cases of elevated risk described above, violate applicable laws, or violate the internal rules of the Service, the Service provider is authorized to refuse to execute or suspend transactions, block the user's account, restrict access to the user's account, possessed virtual items, account balance and tools enabling the trading or removal of virtual items from the Service, or withhold the payment of value to the user, or conduct additional verification and request explanations, or refuse to provide services, or notify the relevant authorities of the suspicion of a crime being committed.
In situations related to refusal to execute, suspension of a transaction, blocking, restriction of access to the account, possessed virtual items, account balance and tools enabling the trading or removal of virtual items from the Service, withholding the payment of asset values, in order to proceed with the lifting of restrictions, the user is obliged to provide the data, information, and documents indicated by the Service provider.
In order to lift the restrictions, the user is obliged to provide the required information and documents. After their analysis, the Service provider may restore full or limited access to the account and virtual assets or enable the deposit of asset values into the Service or the withdrawal of asset values outside the Service's structures, or refuse further provision of services with the transfer to the user of the possessed values and virtual assets, or notify the relevant authorities of the disclosed risk of crime.
In cases giving the Service provider reasonable suspicion of the user's association with criminal activities, the Service provider reports the matter to the relevant authorities.
In the event of failure to provide data, information, or documents at the request of the Service provider, the Service provider is authorized to terminate the relationship with the user and cease providing services to the user. Failure to provide the required data may result in refusal to establish or termination of cooperation without restoring access to services, as well as notification of the relevant authorities of the suspicion of criminal risk.
The Service provider is authorized to immediately terminate cooperation in the event of a reasonable suspicion of criminal activity or violation of generally applicable law or Service regulations, including the terms of service and policies.
The Service provider may retain the values received from the user and the virtual assets possessed by the user until appropriate instructions are provided by law enforcement or government authorities.
The Service provider bears no liability or risk of reduction of the user's assets for actions taken to fulfill legal obligations related to combating crime and cooperating with the relevant authorities. The user, upon granting consents to use the services, accepted these actions and waives claims related thereto, declaring cooperation through the active provision of required information and documents.
The Service provider is not liable for damages suffered by the user due to the performance of the above activities, and the user, by using the Service, declares that they are aware of the purpose of the Service provider's proceedings and expresses willingness to cooperate in this regard, including by actively providing necessary materials.
The Service provider bears no liability for the user's instruction to withdraw asset values to the accounts or wallets of third parties, or for granting access to the account to third parties and performing activities under the influence and at the instruction of third parties, which individual users accept upon using the services of the Service.
The Service provider is not responsible for the transfer of the user's value into the Service's structures and the withdrawal of value outside the Service's structures, where the entities responsible, also in terms of crime prevention, are the operators processing the transfers, which users accept upon using the services of the Service. Operators executing deposits and withdrawals of value are often obligated institutions within the scope of AML regulations and may block value within their internal regulations and procedures.
In cases aimed at preventing the use of the services offered within the Service for criminal purposes, reports should be sent to the following email address: [email protected].
Contact with the Service provider by law enforcement or government authorities is also possible via the above email address.
