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Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

1. Regulatory Framework and Commitment

This Anti-Money Laundering and Know Your Customer Policy (“Policy”) sets out the standards applied by Mobile Incorporated Limited (the “Company”, “we”, “us”, or “our”) to prevent the misuse of its services for money laundering, terrorist financing, fraud, or any other form of financial crime.

The Company operates under a B2C Gaming Service Licence issued by the Malta Gaming Authority (MGA) and is classified as a subject person under Maltese Anti-Money Laundering and Counter-Terrorist Financing legislation.

Accordingly, the Company applies a risk-based compliance framework designed to identify, assess, mitigate, and report financial crime risks across its customer base and transactional activity.

This Policy applies to all users of the Company’s gaming and betting services.

2. Customer Due Diligence (CDD)

2.1 Identity Verification

Prior to, or during, the establishment of a business relationship, the Company is required to verify the identity of each customer.

This includes:

  • Collection of valid government-issued photographic identification
  • Verification of full legal name, date of birth, and residential address
  • Confirmation that the customer meets the minimum legal age requirement of 18 years

Verification may be conducted through automated electronic verification tools or manual document review processes using reliable and independent sources.

Where verification cannot be satisfactorily completed, the Company reserves the right to restrict, suspend, or decline account functionality.

2.2 Enhanced Due Diligence (EDD)

Where higher levels of risk are identified, the Company applies Enhanced Due Diligence measures.

These circumstances include:

  • Classification of a customer as high-risk
  • Identification as a Politically Exposed Person (PEP)
  • Unusual or high-value transactional activity
  • Unclear or insufficient source of funds or wealth
  • Elevated geographical or jurisdictional risk indicators

EDD measures may include:

  • Requesting additional documentation
  • Independent verification of provided information
  • Source of funds and wealth validation
  • Senior Management approval prior to continuation of the relationship

3. Source of Funds and Financial Assessment

The Company may require customers to provide supporting evidence demonstrating the legitimacy of funds used on the platform.

Acceptable documentation may include:

  • Bank account statements
  • Employment confirmation or payslips
  • Corporate ownership or business records (where relevant)
  • Asset sale agreements or similar financial records

Pending satisfactory review, the Company may temporarily limit deposits, withdrawals, or account activity.

4. Transaction Monitoring and Suspicious Behaviour Detection

The Company operates both automated systems and manual oversight processes to monitor customer activity.

Monitoring is designed to detect:

  • Unusual or inconsistent deposit and withdrawal behaviour
  • Rapid movement of funds in and out of accounts
  • Structuring or layering patterns
  • Betting or gaming behaviour inconsistent with expected profile

All alerts are reviewed by qualified compliance personnel.

Where concerns arise, the Company may:

  • Request further information or documentation
  • Restrict or suspend account activity
  • Escalate the matter internally for review
  • Submit a Suspicious Activity Report (SAR) where required

5. Sanctions Screening and PEP Checks

All customers are screened against relevant international and national databases, including:

  • EU consolidated sanctions lists
  • United Nations sanctions lists
  • Applicable national sanctions registers
  • Politically Exposed Person (PEP) databases

Screening is performed at onboarding and repeated periodically throughout the business relationship.

6. Regulatory Reporting Obligations

Where the Company knows, suspects, or has reasonable grounds to suspect money laundering or terrorist financing activity, it is required to submit a Suspicious Activity Report (SAR) to the Financial Intelligence Analysis Unit (FIAU) in accordance with Maltese law.

The Company strictly prohibits any form of tipping-off to customers or third parties.

The Company fully cooperates with:

  • The FIAU
  • The Malta Gaming Authority (MGA)
  • Law enforcement authorities

7. Record Keeping and Retention

In compliance with applicable AML/CTF regulations, the Company retains records including:

  • Customer identification and verification data
  • Transaction and account activity records
  • Risk assessments and monitoring outputs
  • Suspicious Activity Reports and related documentation

All records are retained for a minimum period of five (5) years following the end of the business relationship or last transaction, whichever is later.

8. Risk-Based Assessment and Ongoing Monitoring

The Company applies a risk-based approach to both onboarding and ongoing customer monitoring.

Customers are assessed and classified according to factors such as:

  • Geographic exposure
  • Transaction size, frequency, and behaviour
  • Account usage patterns
  • Other behavioural or risk indicators

High-risk customers are subject to Enhanced Due Diligence and more frequent monitoring.

The Company prepares periodic compliance and risk reports, which may be submitted to the MGA in accordance with licensing requirements.

9. Customer Obligations

Customers are required to:

  • Provide accurate, complete, and truthful information during registration
  • Maintain up-to-date account and identity information
  • Provide additional documentation upon request for AML/KYC purposes

Failure to comply with verification or AML/KYC requirements may result in:

  • Suspension of account access
  • Restriction of deposits or withdrawals
  • Closure of the account

All actions are taken in accordance with applicable regulatory obligations.

10. Internal Governance, Controls, and Training

The Company maintains a structured AML governance framework including:

  • Appointment of a Money Laundering Reporting Officer (MLRO)
  • Documented internal AML/CTF procedures
  • Defined escalation and decision-making protocols
  • Regular employee training programmes

The effectiveness of the AML control framework is reviewed on a periodic basis.

11. Data Protection and Information Security

All personal and financial information collected under this Policy is processed in accordance with applicable data protection laws, including GDPR and relevant regulatory standards.

The Company ensures:

  • Secure storage of personal data
  • Restricted access to authorised personnel only
  • Controlled sharing with regulatory and legal authorities where required
  • Protection of confidentiality, integrity, and availability of data

AML and KYC records are retained for at least five (5) years after the end of the business relationship, in accordance with regulatory requirements.

12. Withdrawal Conditions and Identity Verification Threshold

The Company applies conditions to withdrawals as part of its AML and fraud prevention framework.

Withdrawals may be subject to identity verification requirements, including where a customer’s cumulative deposits exceed €2,000.

This threshold may be calculated using either:

  • a daily cumulative basis, taking into account all deposits made by the customer from the commencement of the business relationship; or
  • a rolling period of one hundred and eighty (180) days, aggregating deposits within that timeframe

Where this threshold is reached, the Company may require enhanced identity verification prior to processing withdrawal requests.

Failure to complete required verification may result in delays or restrictions on withdrawal processing.

13. Policy Updates

This Policy may be amended from time to time to reflect changes in legal, regulatory, or operational requirements.

The most current version will always be made available through the Company’s official website or customer information channels.