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Anti-Money Laundering (AML) & Combating the Financing of Terrorism (CFT)-Compliance Policy

1. Scope and Legal Effect

This Anti-Money Laundering and Counter-Terrorist Financing Policy (“Policy”) establishes the legal framework governing the prevention, detection, and reporting of money laundering (“ML”) and terrorist financing (“TF”) activities on the platform.

This Policy:

  • Applies to all users (“You”) accessing or using the services
  • Applies to all accounts, transactions, and related activities
  • Forms an integral and binding part of the Terms of Use

By accessing or continuing to use the services, you:

  • Irrevocably acknowledge and agree to be legally bound by this Policy

2. Legal and Regulatory Framework

We implement an AML/CFT framework in accordance with:

  • Applicable laws and regulatory obligations
  • International AML/CFT standards, including FATF recommendations
  • Reporting obligations to competent authorities

This Policy is designed to:

  • Prevent misuse of the platform for financial crime
  • Maintain integrity of financial systems
  • Ensure traceability, accountability, and regulatory compliance

3. Definitions

For the purposes of this Policy:

  • “Money Laundering (ML)”: Any act intended to conceal or disguise the origin of illicit funds
  • “Terrorist Financing (TF)”: The provision or collection of funds to support terrorist activities
  • “KYC”: Know Your Customer identification procedures
  • “CDD”: Customer Due Diligence
  • “EDD”: Enhanced Due Diligence
  • “PEPs”: Politically Exposed Persons
  • “UBO”: Ultimate Beneficial Owner
  • “Suspicious Transaction”: Any transaction inconsistent with expected behavior or lacking economic rationale

4. Risk-Based Approach (RBA)

We apply a risk-based approach, whereby:

  • Each user is assessed and classified based on risk profile
  • Controls are proportionate to the level of risk

Risk factors include:

  • Jurisdiction
  • Transaction behavior
  • Source of funds
  • Payment methods
  • Behavioral data

We reserve the right to:

  • Apply enhanced controls for high-risk users
  • Restrict, suspend, or terminate services based on risk exposure

5. Identity Verification (KYC Obligations)

You are required to:

  • Provide accurate, complete, and up-to-date information
  • Complete identity verification when requested

We reserve the right, at any time, to:

  • Request identity documentation (ID/Passport)
  • Request proof of address and source of funds
  • Restrict or suspend account functionality

Failure to comply may result in:

  • Refusal of transactions
  • Account suspension or freezing
  • Termination of services

6. Customer Due Diligence (CDD)

We perform CDD to:

  • Verify identity and legitimacy of users
  • Understand the purpose and nature of business relationships
  • Assess source of funds and financial behavior

All data processing is conducted in accordance with the Privacy Policy

We reserve the right to:

  • Refuse onboarding or continuation of services if information is incomplete or unreliable

7. Enhanced Due Diligence (EDD)

EDD is applied in cases including:

  • High-risk users
  • Large or unusual transactions
  • PEPs
  • High-risk payment methods

EDD measures may include:

  • Source of funds and wealth verification
  • Additional documentation requirements
  • Ongoing monitoring

8. Transaction Monitoring

We implement automated and manual monitoring systems to:

  • Detect unusual or suspicious activity
  • Identify behavioral anomalies

Indicators may include:

  • Large deposits with minimal gameplay
  • Rapid deposit-withdrawal cycles
  • Structuring transactions to avoid thresholds

We reserve the right to:

  • Delay or reject transactions
  • Request additional verification

9. Suspicious Transaction Reporting (STR/SAR)

We are legally obligated to:

  • Report suspicious transactions to competent authorities

We strictly enforce:

  • No tipping-off obligation

You are not entitled to:

  • Be informed of any reporting
  • Interfere with reporting processes

10. Enforcement Measures

In case of AML/CFT risks or violations, we reserve the right to:

  • Freeze accounts
  • Withhold or reject transactions
  • Confiscate funds linked to illicit activity
  • Terminate accounts without prior notice (where legally required)

These measures may be applied:

  • Individually or cumulatively, at our sole discretion

11. User Legal Obligations

You represent and warrant that:

  • All funds are derived from lawful sources
  • You are the beneficial owner of your account
  • You will not use the platform for ML/TF activities
  • You will not structure transactions to evade controls

Any violation may result in:

  • Civil or criminal liability
  • Cooperation with law enforcement authorities

12. Data Retention and Protection

We retain:

  • KYC records
  • Transaction data
  • AML-related documentation

For a minimum period required by law (typically 5+ years)

Data processing complies with:

  • Privacy Policy
  • Applicable data protection laws (e.g., GDPR where applicable)

13. Integration with Responsible Gaming

AML/CFT controls are integrated with player protection measures:

  • Detection of abnormal financial behavior linked to harmful gambling
  • Support for responsible gaming interventions

14. Third-Party Disclosure

We may share data with:

  • Payment providers
  • KYC/verification partners
  • Regulatory and law enforcement authorities

Only where:

  • Necessary
  • Lawful
  • Proportionate

15. Amendments and Validity

We reserve the right to amend this Policy at any time. Changes shall take effect upon publication.

Your continued use of the services constitutes:

  • Binding acceptance of the updated Policy

16. Effective Date

This Policy is effective as of: 12/01/2026