AML Policy

01Purpose and scope

Clubchess is a chess competition platform. It must not be used for money laundering, terrorist financing, sanctions evasion, fraud, or concealing the source or ownership of funds. This Anti-Money Laundering and Counter-Terrorist Financing Policy forms part of the Terms and Conditions.

This policy applies to accounts, Bitcoin deposits and withdrawals, platform balances, Duel entries, tournament entries, prizes, and other value transferred through the service. Amounts are displayed in mBTC; follow the exact Bitcoin network and destination shown in the supported wallet flow.

02No coin mixing or pass-through use

You must not use Clubchess deposits or withdrawals for coin mixing, tumbling, or laundering, or to obscure the source, ownership, movement, or destination of coins. Clubchess is not a mixing service or a general-purpose payment intermediary.

Prohibited use includes depositing and withdrawing primarily to conceal a transaction trail, routing funds through multiple accounts to disguise ownership, arranging games or losses to transfer value, and presenting transfers between cooperating players as legitimate prizes. Do not use another person’s account, misrepresent the owner of funds, split transactions to evade controls, or fund an account with stolen or otherwise unlawful assets.

If we identify or reasonably suspect prohibited mixing or related misuse, we may suspend your account and freeze access to affected funds, including restricting new withdrawal requests, while we review the activity or comply with a binding legal restriction. Confirmed misuse may lead to account closure and further action required by law. The review and funds provisions below apply.

03No identity documents; security checks still apply

Clubchess does not require KYC documents: no government-issued identification, selfie, or proof of address is needed to register, play, deposit Bitcoin, or request a withdrawal. This does not mean activity is anonymous or unrecorded, and it does not permit false account information or misuse of the service.

Withdrawal requests, including your first withdrawal, are processed automatically after authentication and payment checks pass. Password confirmation and two-factor authentication when enabled remain required. Clubchess may hold any withdrawal for manual review if we suspect foul play, including cheating, fraud, account abuse, or other prohibited activity. We may ask for a transaction reference, an explanation of activity, or relevant account or transaction information when investigating a concern.

Staff must never request your private key, seed phrase, password, or authentication code. Do not send identity documents to Clubchess.

04Review of unusual activity

Reviews may consider available transaction and ledger records, game results, account activity, payment exceptions, reports from users, and relevant information supplied during an investigation. A transaction pattern or connection to a wallet is a reason to examine the facts, not proof of wrongdoing on its own.

Clubchess records transactions, processes eligible withdrawals automatically, and uses manual investigation and account restrictions when concerns arise. Automatic payout processing is not automated coin-mixer detection, blockchain-risk screening, or sanctions screening; those integrations are not in place. This policy does not represent that every prohibited transfer will be detected or that any transaction is certified as lawful.

Only authorised personnel may make review decisions. Restrictions should be supported by a recorded reason, have a scope proportionate to the concern, and be reconsidered as new information becomes available. Investigation details that would compromise security or disclose another person’s information may be withheld.

05Account suspension and funds restrictions

Where there is a reasonable basis to suspect prohibited financial use, fraud, account compromise, or a binding legal restriction, Clubchess may suspend or restrict the account and temporarily freeze access to affected funds. In this policy, a freeze means restricting access or new financial requests; it does not transfer ownership of your balance to Clubchess or impose automatic forfeiture.

An account restriction may not stop a withdrawal already approved or submitted for processing. Bitcoin transactions already broadcast cannot be reversed by these controls. We do not promise that a restriction can recover funds already sent to an external address.

A review must have a documented basis and a review timetable. Where disclosure is permitted, we will provide status information, explain what information is needed, and communicate the outcome. If the review takes longer, restrictions must be reassessed and any continuing basis documented. A binding legal hold or confidentiality obligation may limit disclosure or delay release.

Depending on the findings and applicable rights, the outcome may include removing a restriction, declining a transaction, returning funds through a permitted process, closing an account, or maintaining a restriction required by law. Unaffected, lawfully held funds should not remain restricted without a continuing reason. Confirmed misuse is not a blanket right to confiscate a balance.

We will not demand an extra deposit or an invented tax, clearance fee, or release payment to unlock funds. Any legitimate network or transaction fee must follow the ordinary disclosed terms.

06Lawful use and mandatory requirements

Do not use Clubchess to finance terrorism, evade an applicable sanctions restriction, handle criminal proceeds, or violate a binding order. No-KYC access does not override these prohibitions.

Where a binding reporting, recordkeeping, transaction-information, or asset-restriction requirement applies, Clubchess must follow it. Relevant information may be disclosed to a competent authority through a lawful process, subject to applicable confidentiality restrictions. Clubchess does not use automated regulatory-reporting or Travel Rule software.

07Records and privacy

Relevant transaction records, account activity, review decisions, and correspondence may be retained to administer the service, investigate misuse, resolve disputes, comply with binding requirements, or protect legal rights. Access must be limited to authorised persons with a relevant purpose.

Retention depends on the record’s purpose and applicable obligations. A legal hold may require keeping particular records after account closure; it does not justify retaining unrelated information indefinitely. The Privacy Policy explains the information we handle and how to request access, correction, or deletion.

08Questions, appeals, and policy changes

To report suspected misuse or request review of a restriction, email contact@clubchess.net with your username, relevant transaction or game reference, and a factual explanation. Do not include private keys, seed phrases, authentication codes, or identity documents.

Review requests and appeals are handled manually. A different reviewer should consider an appeal where practicable. We will communicate a reasoned outcome where disclosure is permitted. Internal review does not remove your right to seek an independent remedy available under applicable law.

Material changes will be published with an updated version and effective date, with additional notice or acceptance where required. Read this policy together with the Terms and Conditions, Privacy Policy, and Fair-Game Policy.