Transaction Monitoring & Reporting Policy

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

We monitor every transaction made on Get Fire Kirin and Easy Street to prevent fraud, protect players, and comply with financial regulations. Every purchase, redemption, or payout is screened in real time for unusual or risky activity. Suspicious behavior is reviewed by our Compliance Team and, if necessary, reported to regulators under the Bank Secrecy Act (BSA).

1. Purpose

This policy establishes MC Data Solutions LLC’s standards for monitoring, detecting, and reporting suspicious financial activity on the Get Fire Kirin and Easy Street platforms. It ensures compliance with the Bank Secrecy Act (BSA), OFAC regulations, and the requirements of our processors, banking partners, and regulators.

2. Scope

Applies to all:

Player accounts, purchases, redemptions, and AMOE entries.
Crypto and fiat payouts through Simple 8 Wallet (MassPay).
Monitoring and reporting systems (SEON, Veriff, internal audit tools).
Employees, vendors, affiliates, and partners involved in transaction processing.

3. Objectives

Detect and prevent money laundering, fraud, or sanctions evasion.
Maintain transparent, auditable financial records.
Report suspicious activity to authorities as required by law.
Protect player funds and preserve platform integrity.

4. Regulatory Basis

Bank Secrecy Act (31 U.S.C. §5311–5332)
FinCEN AML/CFT Guidance FIN-2019-G001
OFAC Sanctions Regulations (31 C.F.R. §500 et seq.)
FinCEN SAR Filing Rules (31 C.F.R. §1022.320)
USA PATRIOT Act Title III
ISO 37301:2021 Compliance Framework

5. System Overview

5.1 Monitoring Tools

All transactions are automatically screened by SEON, which analyzes:

Purchase and redemption velocity
Device/IP consistency
Payment behavior and chargebacks
Crypto wallet origin, risk, and traceability

5.2 Identity Verification

All redemptions and payouts require Veriff verification (ID match, liveness, and age 21+). Accounts failing verification are locked until resolved.

5.3 Payment Infrastructure

All payouts are handled securely through Simple 8 Wallet (MassPay), with built-in compliance validation, audit logging, and reconciliation.

6. Threshold Controls

Type	Threshold	Action
Purchase Limit	$3,500/day	Compliance review
Payout Limit	$400/day	Hard limit enforced
Crypto Transaction	≥ $10,000	Enhanced Due Diligence (EDD)
AMOE	1 request / 30 days	Duplicate auto-flagged
Inactivity	60 days	Auto account closure

7. Red Flag Indicators

Category	Examples
Purchase Behavior	Rapid purchase/redemption cycles
Device/IP Risk	Multiple accounts per IP/device
Chargebacks	Repeated disputes or reversals
Crypto Activity	Use of high-risk wallets or mixers
Structuring	Breaking up transactions to avoid limits

These red flags automatically trigger alerts through SEON’s system for review and possible escalation.

8. Alert Handling and Review

Step	Description	Responsible Party	Timeline
1	SEON generates alert	Automated	Immediate
2	AML Analyst reviews	Compliance Team	≤ 24 hours
3	Escalation (if warranted)	Compliance Officer	≤ 48 hours
4	SAR filed (if required)	Compliance Officer	≤ 72 hours
5	Record retention	Compliance Department	7 years

9. Suspicious Activity Reporting (SARs)

A SAR is filed when transactions indicate potential fraud, structuring, or AML violations.
Examples: synthetic accounts, high-risk crypto transfers, payout manipulation.
SARs are confidential per 31 U.S.C. §5318(g)(2) — unauthorized disclosure is prohibited.
All SARs and related evidence are retained for seven (7) years.

10. Enhanced Monitoring & EDD Triggers

EDD is initiated for crypto transactions ≥ $10,000.
High-risk accounts or foreign IPs.
Repeated SEON alerts or PEP/adverse media hits.
Suspicious behavioral patterns linked to financial risk.

EDD includes documentation review, source-of-funds verification, and Compliance Officer approval.

11. Continuous Monitoring and Reporting

Daily: SEON risk analysis and transaction flagging.
Weekly: Compliance summary report with risk scoring and SAR statistics.
Quarterly: Legal Memorandum update and trend assessment.
Annually: Independent AML audit and control review.

Findings feed into training and process improvements across all departments.

12. Data Security and Recordkeeping

Record Type	Retention	Security
SEON Alerts	7 years	AES-256 encryption
SAR Files	7 years	Secure SEON portal
Training Records	5 years	Internal LMS
Audit Logs	5 years	Immutable ledger

13. Staff Training and Awareness

All employees involved in payments, compliance, or customer support complete mandatory AML and transaction monitoring training annually.

SEON case handling
SAR confidentiality
Red flag identification
Escalation procedures

Passing score ≥ 90%. Records retained for five years.

14. Cooperation and Transparency

MC Data Solutions LLC cooperates fully with processors, banking partners, and regulatory agencies. Official requests and subpoenas are handled by the Compliance team within required timeframes. We maintain transparency while protecting player privacy and legal confidentiality.

15. Continuous Improvement

The transaction monitoring and reporting program is reviewed quarterly with updates to the Legal Memorandum. Results are documented in the Annual Compliance Report and shared internally for audit readiness and staff training updates.

16. Cross-Policy Integration

This policy works in conjunction with:

Policy #1: BSA / AML & Sanctions Compliance
Policy #2: Responsible Gaming & Fair Play
Policy #4: Customer Risk Rating & Due Diligence
Policy #5: Information Security & Data Protection
Policy #6: Privacy Policy
Policy #7: Terms of Service & Conditions

Contact

MC Data Solutions LLC
compliance@getfirekirin.com
2611 N Belt Line Rd, Mesquite, TX 75182