Anti-Money Laundering & KYC Policy

1. Regulatory framework

Our AML programme is designed to meet the requirements of FATF Recommendations, EU AMLD (4th, 5th, 6th), UK Money Laundering Regulations 2017, and applicable local gambling regulators (MGA, UKGC, etc.).

2. Customer Due Diligence (CDD) tiers

• Tier 1 — Registration: email, DOB, address, IP / device fingerprint, sanctions / PEP screening.
• Tier 2 — Verified: government-issued photo ID, liveness selfie. Required before first withdrawal.
• Tier 3 — Enhanced (EDD): proof of address, source-of-funds documentation. Triggered by thresholds, risk score, PEP status, or unusual activity.

3. Sanctions and PEP screening

All customers are screened against OFAC, EU, UK HMT, and UN sanctions lists at onboarding and continuously thereafter. PEP matches are escalated to compliance for manual review.

4. Transaction monitoring

Automated rules flag rapid deposits, structuring, chip-dumping, geolocation anomalies, and high-velocity wagering. Alerts are reviewed by the compliance team and escalated to MLRO where required.

5. Suspicious Activity Reports

The MLRO files SARs / STRs with the relevant Financial Intelligence Unit (e.g. NCA in the UK, FinCEN in the US) when statutory thresholds are met. Customers are not notified ("tipping off" prohibited).

6. Record keeping

Customer records, transactions, and internal investigations are retained for at least 5 years after the business relationship ends, or longer where required.

7. Training and governance

All staff complete AML training annually. Compliance, MLRO, and Board roles are defined in our internal AML manual.

8. Demo status notice

While the Service operates in demonstration mode, no real-money deposits or withdrawals occur. The KYC scaffolding is fully implemented and will be activated upon licensing and integration with a regulated payment acquirer.