AML Policy

1. Purpose. This KYC Policy outlines the procedures for user registration, identity verification, age compliance, account management, and anti-money laundering (AML) measures for all customers of the Company. The policy is designed to ensure compliance with applicable laws and regulatory requirements.

2. Restricted/Prohibited Jurisdictions. The Company does not accept registrations or allow participation from individuals located in jurisdictions where online gambling is prohibited or restricted by law. The Company maintains a list of such jurisdictions and will block access from these locations. Customers are required to confirm their country of residence during registration, and the Company reserves the right to request proof of location at any time. Accounts found to be in breach of this requirement will be closed and all associated funds may be forfeited.

3. Customer Identification and Verification. To register as a player, an individual must register personally and submit an application for registration, and provide the following information:

Date of birth and valid identification showing the individual is over eighteen (18) years of age or the legal age of majority in their jurisdiction. Identification documents which must be submitted include a copy of a valid passport or other government-issued identification, and a proof of address (e.g., utility bill, bank statement).

• First and last name;
• Full residential address;
• Valid email address;

The Company may request additional documentation and perform further checks to verify the information provided. Accounts may be suspended until satisfactory information is received.

4. Enhanced Due Diligence (EDD) for High-Risk Customers. The Company applies Enhanced Due Diligence measures in the following cases:

• Customers identified as high-risk based on risk assessment criteria (e.g., country of origin, transaction patterns, occupation);
• Customers making large or unusual transactions;
• Customers with complex ownership structures.

EDD measures include, but are not limited to: obtaining additional identification documents; verifying the source of funds and/or source of wealth; conducting adverse media and sanctions screening; and ongoing monitoring of account activity.

5. Politically Exposed Persons (PEPs). The Company identifies and applies additional scrutiny to Politically Exposed Persons (PEPs), their family members, and close associates. PEPs are subject to EDD measures, including:

• Enhanced identity verification;
• Detailed source of funds/source of wealth checks;
• Senior management approval before establishing or continuing a business relationship.

6. Large or Unusual Transactions. The Company monitors all transactions for size, frequency, and pattern. Any large or unusual transactions are subject to review and may trigger EDD procedures. Examples include:

• Single or cumulative transactions exceeding a set threshold;
• Transactions inconsistent with the customer’s known profile;
• Rapid movement of funds in and out of accounts.

Such transactions may be reported to relevant authorities as required by law.

7. Source of Funds and Source of Wealth Checks. Where applicable, the Company will request information and supporting documentation to verify the source of funds and/or source of wealth, especially for high-risk customers, PEPs, or in the case of large/unusual transactions. Acceptable documents include bank statements, payslips, business ownership records, or other evidence as deemed appropriate.

8. Age Verification and Account Management. The Company will suspend accounts if it cannot verify that the customer has reached the eligible age. If a customer is found to be underage, the account will be closed, transactions annulled, and funds returned as per policy. Any winnings accumulated while underage will be forfeited.

9. False or Misleading Information. If information provided by a customer is found to be false, incomplete, inaccurate, or misleading, the Company may immediately close the account, cancel all funds, and take further action as necessary.

10. Document Review Timelines. KYC documents will be reviewed within 30 working days from the date all requested documents are provided.