BSA/AML & Sanctions Compliance

BSA / AML & Sanctions Compliance Statement

MC Data Solutions LLC

(Covers the Get Fire Kirin and Easy Street gaming platforms)

Effective Date: October 25, 2025
Jurisdiction: Texas, United States
Version: 1.0 Web Compliance Edition
Contact: compliance@getfirekirin.com

Summary

At MC Data Solutions LLC, we take your safety seriously. We follow the Bank Secrecy Act (BSA), USA PATRIOT Act, and OFAC sanctions rules to keep Get Fire Kirin and Easy Street free from money-laundering and fraud.

Every player’s identity is verified, every payment and payout is screened for risk, and suspicious activity is reviewed by our Compliance team before funds are released.

Your data is encrypted, never sold, and used only for lawful compliance purposes.

1. Purpose and Commitment

This policy describes how MC Data Solutions LLC complies with U.S. anti-money-laundering laws and sanctions requirements. It ensures that all transactions on Get Fire Kirin and Easy Street are legitimate, traceable, and conducted by verified individuals. Our program follows the Bank Secrecy Act (BSA), USA PATRIOT Act Title III, and OFAC Sanctions Regulations (31 C.F.R. §500 et seq.).

2. Scope and Applicability

This policy applies to all players, employees, vendors, and partners involved with our sweepstakes operations, including:

Platforms: Get Fire Kirin and Easy Street.
Payment Systems: Simple 8 Wallet (MassPay).
Verification Services: SEON (fraud / AML monitoring) and Veriff (ID and age verification).
Compliance Functions: Transaction monitoring, record keeping, and regulatory reporting.

3. Player Identity Verification (KYC)

Age Requirement: 21 years or older.
Verification Steps: Before any payout, Veriff confirms identity, liveness, and age.
Pre-Check: SEON screens every new account using 300+ data points (IP, device, email, behavior).
Failed Checks: Unverified accounts are blocked or suspended immediately.

4. Geolocation and Eligibility Controls

Gameplay and payouts are not available in the following U.S. states:

Arizona, Arkansas, California, Connecticut, Delaware, Hawaii, Idaho, Louisiana, Maryland, Michigan, Mississippi, Montana, Nevada, New Jersey, New York, Pennsylvania, Virginia, and Washington.

SEON automatically blocks access from VPNs, proxies, or restricted regions.
The blocked-state list is reviewed quarterly under our Legal Memorandum process.

5. Transaction Monitoring and Fraud Detection

All purchases, AMOE entries, and payouts are continuously monitored through SEON. We look for red flags such as unusual spending patterns, multiple accounts, or rapid withdrawals.

Alerts are reviewed by trained AML analysts and escalated to Compliance for investigation. If activity appears suspicious, a Suspicious Activity Report (SAR) is filed as required by law.

6. Ongoing Monitoring and Reporting

Daily: Automated fraud screening via SEON.
Weekly: Sanctions list re-checks (OFAC, EU, UN).
Quarterly: Risk trend and blocked-state reviews.
Annually: Independent AML audit and training verification.

Compliance monitoring is continuous and documented for audit purposes.

7. Data Security and Privacy

All personal and financial information is encrypted using AES-256 at rest and TLS 1.3 in transit. Access is restricted to authorized Compliance staff via multi-factor authentication and role-based controls.

Records are retained for five (5) to seven (7) years as required by law, then securely deleted or anonymized.
See our Privacy Policy and Information Security Policy for details.

8. Cryptocurrency and High-Value Transactions

Crypto payouts through Simple 8 Wallet (MassPay) are subject to enhanced due diligence. Transactions ≥ $10,000 receive manual review and documented approval. Blockchain addresses are screened for risk indicators (e.g., mixers or sanctioned wallets). Records are retained seven (7) years.

9. Regulatory Cooperation

MC Data Solutions LLC cooperates fully with FinCEN, OFAC, law enforcement, and financial partners. All subpoenas and official requests are reviewed and fulfilled by Compliance within legal timeframes. Investigations are confidential and logged for regulatory audit.

10. Training and Accountability

All employees complete annual AML/KYC and sanctions training with a minimum passing score of 90%. Training records are reviewed quarterly and retained for five years.

Employees and partners may confidentially report concerns to compliance@getfirekirin.com; all reports are reviewed within 72 hours.

11. Continuous Improvement

The AML and Sanctions program is reviewed every quarter along with updating the legal memo to stay current with laws and technology. Findings from each review are integrated into training and policy updates.

Contact

MC Data Solutions LLC
compliance@getfirekirin.com
2611 N Belt Line Rd, Mesquite, TX 75182
OFAC Hotline: 1-800-540-6322