AML/CFT Policies

To comply with relevant rules, regulations, and global standards, the Company has implemented a set of procedures that it adheres to when delivering services to account holders. These procedures encompass a range of criteria, such as customer due diligence, know your customer, the money laundering reporting officer, risk management, risk classification, monitoring of account holder activities, reporting of unusual transactions, and recordkeeping.

Risk Management & Risk Classification

The Company adopts a risk-based approach to effectively detect and prevent any potential risks, such as money laundering, terrorist financing, or fraudulent transactions, associated with its clients.

The Company's risk classification framework includes two categories:

• Low Risk. All players are classified as low risk, and they are subject to standard due diligence procedures, including the provision of Know Your Customer (KYC) documentation as per the process described above and constant monitoring of account activities.
• High Risk. The player's activity is the primary factor in determining the high-risk classification. If an automated alert has been generated or inappropriate activity has been detected, the player will be classified as high risk, and an enhanced due diligence procedure will be followed. Some instances that may warrant a high-risk classification include but are not limited to those mentioned above.

Customer Due Diligence

Know Your Customer (KYC)

Identification & Verification

In accordance with international standards and local laws, it is essential for a company to have knowledge of its clients. A robust Know Your Customer (KYC) policy and procedure are critical in safeguarding the stability and security of a company and the financial system. To this end, the Company has put in place the following procedures:

KYC Information Request

No individual is permitted to participate in a game involving money unless he or she has registered and been provided with a Player Account. Only one Player Account is allowed per person, family, and shared environment. To register as a player, the individual must provide the following KYC information:

1. Date of birth along with valid identification showing that he or she is over eighteen (18) years of age or the applicable legal age of majority as stipulated in the jurisdiction of your residence. The identification documents that must be submitted include a copy of a valid passport, copy of other identification paper, and a proof of address.
2. Player's first and last name.
3. Player's full residential address.
4. Player's valid email address.
5. Payment details.
6. A username and a password.

Upon registration, a geographical location check is performed on the applicant's computer IP to ensure that the individual is in a permitted jurisdiction. If the applicant is not in a permitted jurisdiction, he or she will not be allowed to proceed with the registration process. The Company then reviews the information provided and may request additional documentation to verify the information provided. The Player Account may be put on hold until satisfactory information is received or terminated if the Company finds the information contained in the Player Account to be false or misleading.

The Company reserves the right to refuse to open or close a Player Account at its discretion following a review of the provided KYC information.

Log in details

Sharing login details to access the system with a third party is strictly prohibited for Players. The Company retains the right to cancel a Player Account without issuing a refund if the login details have been disclosed to a third party.

Due Diligence

Standard Due Diligence

In order to verify the identity of the Player, the Company requires certain information such as a valid passport or a driver’s license, as well as a recent copy of a utility bill or bank statement. This process can be conducted during onboarding, upon a withdrawal request, or any time at the discretion of the Company.

The Company also reserves the right to conduct phone verifications of the Player Account, which may include verifying details such as name, home address, email, phone number, photo ID, payment methods, bet types, amounts, and event details. If the verification is unsatisfactory due to fake, false, incorrect, misleading, non-existing, or unverifiable details, the Company may close the Player Account and confiscate any winnings.

Enhanced Due Diligence

Enhanced Due Diligence is a higher level of scrutiny and verification conducted on Players who are classified as High Risk. The Company requests additional KYC information, which may include a driver's license or valid passport, a selfie of the Player holding the identification document, a recently issued utility bill or bank statement, a bank statement showing the initial deposit, and a bank statement no older than three months from the bank to which a withdrawn amount should be deposited. Additionally, information regarding the source of wealth may also be requested.

Enhanced Due Diligence is applied in the following instances:

1. if the Player is a national of a High-Risk Country or the geographical location check at onboarding shows that the Player is residing in a Non-reputable or High-Risk Jurisdiction;
2. upon suspicion of a Player attempting to or having created multiple Player Accounts in multiple different names;
3. upon suspicion of Player(s) being part of a syndicate of Players colluding to gain an advantage over the Company;
4. upon suspicion of the Player being a politically exposed person (PEP);
5. at the detection of any irregular, suspicious, inappropriate, or fraudulent activity;
6. anytime at the discretion of the Company.

If the Company is unable to verify the identity of the Player based on the provided documentation and further efforts, the Company reserves the right to put the Player Account on hold pending the provision of verification information or to terminate the account if it finds the information contained in the Player Account to be false or misleading.

The Money Laundering Reporting Officer (MLRO)

The MLRO plays a critical role in ensuring compliance with anti-money laundering and counter-terrorism financing regulations. The MLRO is responsible for overseeing the review and monitoring of KYC information and Player Account activities, maintaining a list of registered Account Holders, providing training to relevant staff, and cooperating with relevant authorities to prevent and detect criminal activity.

In addition, the MLRO ensures that the Company's KYC policy is adhered to, regularly reviewed, and updated as needed. The MLRO is the key point of contact for regulatory agencies, law enforcement, and other relevant authorities in relation to anti-money laundering and counter-terrorism financing matters.

The MLRO works closely with other personnel involved in KYC procedures and may escalate any suspicious or unusual transactions or activities to relevant authorities for further investigation. The MLRO may also be involved in the implementation of additional due diligence measures for high-risk players or transactions.

The Monitoring of Account Holder activities

Designated personnel are responsible for reviewing and monitoring Player Accounts for any signs of irregular, suspicious, inappropriate, or fraudulent activity, and will conduct investigations if necessary. Security technologies are in place to generate automated alerts which are thoroughly investigated by the team.

If any irregular, suspicious, inappropriate, or fraudulent activity is detected or attempted, the associated Player will be classified as High Risk, and enhanced due diligence (EDD) procedures will be implemented.

Player accounts are regularly reviewed and monitored for various situations, including the provision of fake, false, misleading, or unverifiable KYC information, the use of fictitious names that obscure the true beneficial owner, inappropriate or fraudulent activity, and irregular player activity such as placing zero-risk or even bets.

Other situations that may trigger a review include complex or large transactions that may be related to money laundering or terrorist financing, players suspected of creating multiple accounts in different names, players suspected of colluding to gain an advantage over the Company, and any other irregular, suspicious, inappropriate, or fraudulent activity that may be detected.

Additionally, the use of software programs endowed with artificial intelligence, attempting to break into or circumvent the security measures set up by the system, and logging in from a non-reputable or high-risk jurisdiction are all strictly prohibited.

Specific attention is paid to the following instances:

Multiple Accounts

The Company closely monitors for instances of multiple accounts and take appropriate action when necessary. Players are only allowed to have one account per person, family, or shared environment, such as a house or building, mailing address, phone number, IP address, or device. If the Company suspects that a player has created multiple accounts under different names, or is part of a group colluding to gain an unfair advantage, the Company will temporarily suspend all related accounts and conduct an investigation.

The investigation will include a review of playing history, IP location histories, and the use of computer sharing technology. If it is determined that a player or group of players has created multiple accounts and is playing as part of a syndicate, the Company reserves the right to withhold any cash or bonus winnings and to withhold deposited funds.

When a player requests a withdrawal, the Company will check for the presence of multiple accounts and whether a false proxy was used. If multiple accounts are found, all accounts will be closed and the player will be denied the opening of a new account.

Unusual Activities

In the event that the Company detects unusual deposits or activities in an Account Holder's account, the Company will conduct an investigation and may request additional information from the Account Holder. The account will be suspended until the required documentation is provided. If the Account Holder fails to provide satisfactory information within 30 days, the account will be terminated. The MLRO (Money Laundering Reporting Officer) will then report the unusual transaction to the appropriate authority.

Withdrawal or Pay out of funds

The Company has established clear procedures for the withdrawal or payout of funds. Withdrawal requests must be made through a Player Account, and the Company will request KYC documentation to verify the Player's identity. The Company will only transfer or pay out funds to the Player and will not deposit withdrawn funds to another source.

Before processing any withdrawals, the Company will conduct a review of the Player Account for any unusual activity, such as possible money laundering or suspicious play. Instances of unusual activity may include the placement of a deposit without placing any bets or the creation of multiple Player Accounts in multiple names. The Company may decide to withhold funds and request further documentation or conduct an investigation, suspend the Player Account, block access to the system or the account, or terminate the Player Account and report the activity to the relevant authority as further described below.

Transactions using Cryptocurrency

Cryptocurrency transactions on this platform require that the first deposit be made with a cryptocurrency. After this, all transactions (deposits, wagers, and payouts) must be conducted with the same cryptocurrency. The company is not authorized to sell, buy, or exchange cryptocurrency with or to FIAT currency. To comply with regulations set by the Master License Holder, the company must collect and verify the Player's identity, age, and address. Hardware KYC will be collected and stored at every step from signup to withdrawals to ensure that all transactions are from/to the same Player.

The Master License Holder has further required that the company provide proof of balance as acceptable to ensure that Player's funds are deposited. Solvency proof must be provided periodically to cover all bets and jackpots, and the cryptocurrency must be kept in a separate account. The rate of exchange from cryptocurrency to FIAT currency must be displayed on the website's homepage, and the company cannot exchange cryptocurrency with any FIAT currency. Additionally, the company must inform Players that cryptocurrency values may fluctuate significantly based on market value.

The platform adheres to anti-money-laundering regulations, allowing Players to deposit money solely to play and use the services. Withdrawing winnings is the only way Players can withdraw funds from their accounts, and funds will be blocked if deposited and withdrawn without any gaming activities. The company is not a financial institution and does not offer interest on deposits. Payment method restrictions may apply in certain countries or for specific Players, which the company may apply at its discretion.

The platform will notify Account Holders of new payment methods via e-mail and update the Manual and Terms and Conditions on the Website for each new depositing method. The company will display the exchange rate from cryptocurrency to FIAT currency on the website's homepage and inform Players that cryptocurrency values are subject to market fluctuations. Overall, the company complies with various requirements and regulations to provide secure and reliable cryptocurrency transactions for Players.

Security Review

The Company holds the right to verify the identity, age, and registration data of the Account Holder through a review process to ensure compliance with the Terms and Conditions and applicable laws. Upon registration, the applicant consents to the Company's verification checks and authorizes the Company to conduct relevant inquiries and disclose information to any third party necessary to verify the use of the provided services. The Company may engage third-party agencies to confirm age, identity, address, and payment details, order credit reports, or verify information against public or private databases. All applicant/ Account holders accept that their provided information may be used, recorded, and disclosed by the Company or a third party engaged.

The Company reserves the right to perform reviews periodically at their discretion, for regulatory, security, or other business reasons. During the review process, the Customer may be restricted from withdrawing funds from their account and/or accessing certain Services on the website.

Reporting of Unusual Transactions

The Company is committed to complying with all relevant laws and regulations regarding money laundering and illegal activities. Any transaction that does not have sufficient verifying information or appears to be related to criminal activities will be flagged and reported to the Financial Intelligence Unit (FIU) in Curacao. The Money Laundering Reporting Officer (MLRO) is responsible for this reporting and will maintain a record of all instances where the Company did not find it necessary to report to the FIU. In such cases, the MLRO will provide sufficient justification for the decision not to report.

The Company will take all necessary measures to prevent the use of its services for any illegal or criminal activity. This includes monitoring all transactions and verifying the identity and source of funds of all Account Holders. The Company also reserves the right to refuse any transaction that is suspected of being related to money laundering or other illegal activities. Account Holders are required to cooperate with the Company in all reasonable requests for information and verification in order to prevent any misuse of its services.

Recordkeeping

The Company has a record-keeping obligation to maintain relevant documents in a separate database for at least five years after ending a business relationship. The records should be maintained in a manner that enables investigating authorities to trace individual transactions including transaction amounts, currencies, and types. The Company must ensure that its records are reliable, accurate, and up-to-date.

The Company can provide copies of its records maintained in specific circumstances if ordered by the rule of law and permitted by national law and relevant authorities. In such situations, the Company may have to share records with law enforcement agencies or regulatory authorities. The Company will provide records in accordance with the applicable data protection and privacy laws and regulations.

Staff Due Diligence

To maintain high levels of integrity among its staff, the Company follows a rigorous recruitment process. All job applicants are required to submit their curriculum vitae along with at least two references and relevant educational or professional certificates. The Human Resources Department of the Company then verifies and checks the submitted documentation before making a hiring decision.