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AML & Compliance Policy

1. Introduction

Sunwin is owned and operated under the supervision of the Government of Curaçao, holding a valid gaming license issued by the Curaçao Gaming Authority (CGA). Sunwin operates in full compliance with applicable Curaçao laws and regulations, including but not limited to:

  • National Ordinance on the Identification of Clients (NOIS);
  • National Ordinance for the Reporting of Unusual Transactions (NORUT);
  • AML/CFT Guidelines for Online Gaming Operators issued by the Curaçao Gaming Authority.

This means Sunwin fully complies with all anti-money laundering and legal compliance requirements set by the CGA and international standards. We are committed to operating legally, transparently, and protecting the platform from being exploited for illegal financial activities.

This AML & CFT Compliance Policy is established to ensure Sunwin's continuous compliance with Curaçao laws and best practices in anti-money laundering, consistent with the recommendations of the Financial Action Task Force (FATF) and EU AML Directives.

2. Objectives

Sunwin's Anti-Money Laundering and Counter-Terrorist Financing (AML & CFT) Policy aims to achieve the following key objectives:

  • Prevent the exploitation of Sunwin's platform for money laundering, terrorist financing, or other financial crimes;
  • Protect the integrity of the financial system and safeguard legitimate players from negative impacts arising from illegal activities;
  • Strictly comply with all applicable Curaçao laws and international AML/CFT standards;
  • Maintain legal reputation and brand image through transparent, responsible operations with clear accountability mechanisms; and
  • Actively cooperate with the Curaçao Gaming Authority (CGA), Financial Intelligence Unit Curaçao (FIU Curaçao), and other competent authorities to contribute to global efforts in combating financial crime.

3. Definitions

  • Money Laundering (ML): The act of concealing the origin or ownership of funds obtained from illegal activities to make them appear to have a legitimate source.
  • Terrorism Financing (TF): The provision of funds, assets, or other resources to support, directly or indirectly, terrorist activities.
  • Politically Exposed Persons (PEPs): Individuals holding important public positions, including family members or close associates of such individuals.
  • Ultimate Beneficial Owner (UBO): The individual(s) who ultimately owns or controls a customer or legal entity.
  • Third Party: Any customer, supplier, business partner, agent, or government agency interacting with Sunwin.
  • Risk-Based Approach (RBA): A method of identifying, assessing, and prioritizing risks related to money laundering and terrorist financing, thereby applying control measures commensurate with the risk level.
  • Suspicious Transaction: Any activity that does not match the customer's usual behavior, has no clear economic purpose, or shows signs related to money laundering or terrorist financing.

4. Control Measures

Sunwin has implemented a comprehensive AML/CFT program with strict internal control mechanisms to detect and prevent money laundering, in accordance with NOIS, NORUT, and CGA AML Guidelines. These measures are proportionate to the risks associated with online betting and gaming, designed within the Curaçao legal framework and international best AML practices.

Specifically, Sunwin implements the following:

4.1. Identity Verification and KYC Process

All customers are required to undergo a Know Your Customer (KYC) process to confirm identity, age, and residential address at the time of account registration. Sunwin checks and verifies user personal information against government-issued documents, including but not limited to: ID Card/Citizen Identity Card, Passport, Driver's License, etc. Where necessary, Sunwin may request additional documents to verify address, such as utility bills (electricity, water, internet) or bank statements showing the customer's name and address.

4.2. Customer Due Diligence (CDD) and Risk Assessment

Sunwin applies a Risk-Based Approach (RBA) in Customer Due Diligence (CDD). Accordingly, customers are classified into low, medium, or high-risk groups based on factors including: Country/region of residence or operation; Transaction behavior and patterns; Payment methods used; Indicators related to source of funds and wealth.

4.3. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is automatically applied to high-risk customers, including but not limited to: Politically Exposed Persons (PEPs); Users performing large, unusual transactions or those inconsistent with their risk profile; Customers using cryptocurrency.

EDD measures may include: Collecting additional identification documents; Verifying source of funds and/or source of wealth; Enhanced monitoring of customer activities and transactions.

Customer risk profiles are reviewed periodically and immediately upon trigger events, such as changes in transaction behavior, payment methods, or significant personal information.

4.4. Transaction Monitoring and Review

Sunwin employs advanced technology systems to monitor transactions in real-time and periodically to automatically detect suspicious patterns. Red flags include but are not limited to: Large deposits with minimal gameplay followed by quick withdrawals; Withdrawals immediately after deposits with little or no activity; High-frequency deposit-withdrawal cycles; Structuring transactions to avoid reporting thresholds.

The system automatically triggers alerts when detecting: Transactions exceeding certain value thresholds (e.g., cumulative transactions exceeding the equivalent of 4,000 ANG, as per Curaçao regulations); or Any activity showing signs of deliberate structuring to avoid detection. These alerts are manually reviewed by the Compliance Team to assess and decide on appropriate actions, including: Temporarily freezing the account; Requesting additional information or documents; Applying further control measures per current AML/CFT policy.

4.5. Suspicious Transaction Reporting (STR/SAR)

As a legal obligation, Sunwin will promptly report any activity or transaction suspected of being related to money laundering or terrorist financing to the Financial Intelligence Unit Curaçao (FIU Curaçao) or relevant authorities. Sunwin strictly adheres to the "No Tipping-Off" principle: We do not inform customers that they are under investigation or have been reported; All reporting and investigation activities are kept strictly confidential to avoid influencing or hindering official investigations. Compliance ensures: Investigations are not compromised; Sunwin cooperates fully and lawfully with regulatory and law enforcement agencies.

4.6. Record Keeping and Data Security

All customer KYC records, transaction information, and AML/CFT-related reports are securely stored in Sunwin's system for a minimum of 5 years or longer, as required by applicable law. Sunwin commits to full compliance with personal data protection regulations, including GDPR where applicable, ensuring: Personal data is provided to authorities only upon legal request; Data access, processing, and sharing are performed for proper purposes and within necessary scope.

Sunwin implements strict security measures, including: Data encryption during storage and transmission; Role-based access control; Periodic security vulnerability assessments and intrusion prevention. These measures aim to prevent data leaks, unauthorized access, or misuse, ensuring customer information safety and system integrity.

4.7. Compliance Officer and Staff Training

Sunwin has appointed a senior AML Compliance Officer, also known as the Money Laundering Reporting Officer (MLRO), responsible for overseeing the company's entire AML/CFT framework. The MLRO: Has direct access to senior management; Has independent authority to submit Suspicious Transaction Reports (STR/SAR) to FIU Curaçao without interference.

Sunwin implements a mandatory AML training program for all employees, covering: Current AML/CFT policies; Risk indicators and signs of money laundering or terrorist financing; Internal handling and reporting processes. Training is documented, evaluated, and updated periodically to ensure Sunwin staff remain fully aware, compliant, and maintain high vigilance in anti-money laundering efforts.

5. User Obligations

To maintain a safe, transparent, and legally compliant gaming environment, Sunwin requires all users to fulfill the following obligations:

  • Provide Accurate Information: Users must provide honest and complete information.
  • Identity Verification (KYC): Users must complete verification steps as required.
  • Legitimate Source of Funds: Users must ensure funds are from legal sources.
  • Personal Account, Non-transferable: Accounts are for personal use only and cannot be transferred.
  • No Player-to-Player Transfers: Direct transfers between players are generally prohibited to prevent money laundering.
  • Self-monitoring of Account Activity: Users should regularly check their account history.
  • Compliance with Terms and Laws: Users must adhere to all platform terms and applicable laws.

6. Role of Monitoring System

Sunwin's transaction monitoring system plays a central role in our AML/CFT framework. Automated monitoring tools are designed and configured based on a risk-based approach, aligned with Curaçao Gaming Authority (CGA) guidelines and industry-recognized standards.

This system continuously analyzes transaction data and user behavior to detect anomalies, deviations from expected patterns, and identified money laundering methods. System-generated alerts are promptly reviewed by Compliance personnel under the direct supervision of the MLRO.

This monitoring framework is reviewed periodically and updated regularly to reflect: Regulatory changes, Emerging risks, Operational experience. AML/CFT reports generated from the monitoring system support management oversight and fulfill reporting obligations to regulators.

7. Cooperation with Law Enforcement

Sunwin cooperates fully and proactively with the Curaçao Gaming Authority (CGA), Financial Intelligence Unit Curaçao (FIU Curaçao), and other competent authorities. Upon legal request, Sunwin will promptly and controllably provide relevant records, transaction data, and customer information within the requested scope.

All information disclosure is fully documented, has a clear legal basis, and is conducted in strict compliance with personal data protection regulations. The company prioritizes rapid response to investigation requests, monitoring, and enforcement measures from regulatory and law enforcement agencies.

8. Commitment to Transparency

Sunwin is committed to maintaining transparency in all operations, public disclosures, and user communication. Information regarding operating licenses and significant legal compliance updates is publicly disclosed.

Mọi giao dịch tài chính đều được ghi nhận rõ ràng, and the entire identity verification and withdrawal process is transparently communicated to players. Sunwin maintains open and proactive cooperation with regulators and promptly addresses all findings, requests, or recommendations from authorities.

Through these measures, Sunwin affirms its commitment to legal, transparent, and responsible operations under the supervision of the Government of Curaçao.

9. Evaluation

Sunwin is committed to ensuring that the AML & CFT Compliance Policy and related procedures remain effective and fully compliant with applicable Curaçao laws and regulatory requirements. This policy will be formally reviewed and evaluated at least once a year, or immediately upon regulatory updates or material changes, whichever comes first.