The policy aligns with:

Financial Action Task Force (FATF) Recommendations

EU 5th/6th AML Directives (where applicable)

Proceeds of Crime and Terrorist Financing Acts in our operating jurisdictions

Verify the identity of all customers (players) before establishing a business relationship.

Monitor customer transactions to detect and report suspicious activity.

Maintain accurate and up-to-date customer information and transaction records.

Train staff to recognize and handle suspicious activities appropriately.

Cooperate with regulatory and law enforcement authorities as required.

Before allowing deposits, withdrawals, or gameplay with real funds, players must complete identity verification. Acceptable documents include:

Proof of Identity: Government-issued photo ID (passport, national ID card, or driver’s license)

Proof of Address:: Utility bill or bank statement issued within the last 3 months

Proof of Payment Method Ownership: Screenshot or statement showing player’s name and payment account details

EDD is applied when:

The player deposits or withdraws amounts exceeding €2,000 (or equivalent) in aggregate

The player is from a high-risk jurisdiction

There are signs of suspicious behavior or inconsistent gameplay patterns EDD measures include:

Video call verification

Source of funds/source of wealth documentation

Ongoing monitoring of all transactions

All players are risk-rated (low, medium, high) based on:

Geographic location

Volume and frequency of transactions

Payment methods used

Behavior patterns (e.g. multiple accounts, rapid deposits/withdrawals)

High-risk players are subject to increased monitoring and additional verification requirements.

Automated systems review deposits, withdrawals, and betting patterns

Unusual behaviors (e.g. rapid turnover, minimal gameplay, large deposits with immediate withdrawals) are flagged for manual review

Any account suspected of involvement in ML/TF is suspended pending investigation

Staff must immediately report suspicious transactions or behaviors to the Money Laundering Reporting Officer (MLRO)

The MLRO will file a Suspicious Activity Report (SAR) to the relevant Financial Intelligence Unit (FIU) as required by law

The player will not be notified that a report has been filed (tipping off is prohibited)

All KYC documents and transaction records are retained securely for a minimum of 5 years after the end of the player relationship

Access to these records is restricted to authorized compliance personnel

Players are screened against PEP and sanctions lists during onboarding and periodically thereafter

PEPs require senior management approval and EDD

No business will be conducted with persons or entities on international sanctions lists (OFAC, EU, UN, etc.)

All customer-facing, financial, and compliance staff receive initial and annual AML/KYC training

Training includes recognizing suspicious behavior, reporting procedures, and legal obligations

The MLRO is responsible for implementing and enforcing this policy

Internal audits are conducted annually to assess the effectiveness of AML/KYC controls

This policy is reviewed at least once per year and updated as required by law

Any employee who fails to comply with this policy may be subject to disciplinary action, up to and including termination

Breaches may also result in regulatory penalties or criminal prosecution

Approved by: Mark Martin, Compliance Officer / MLRO

Effective Date: 17/08/2025

Next Review Date: 17/08/2026