KYC Policy
1. Introduction and Purpose
3-102-968695 S.R.L., with registered number 3-102-968695, having registered address at: PROVINCIA 01 SAN JOSE, CANTON 15 MONTES DE OCA, DISTRITO UNO DE SAN PEDRO, LOS YOSES, AVENIDAS OCHO Y DIEZ, CALLE TREINTA Y NUEVE, LY CENTER (the "Company") adheres to, and complies with, Know Your Customer ("KYC") and Anti-Money Laundering / Counter-Terrorist Financing ("AML/CTF") principles aimed at preventing financial crime, money laundering and terrorist financing through customer identification and due diligence.
This Policy establishes the mandatory standards, controls and obligations applicable to the Company as a condition of its Anjouan Internet Gaming License (No. [ALSI-202608056-FI2), issued by Anjouan Licensing Services Inc., operating as Anjouan Gaming, the competent licensing and supervisory authority acting on behalf of the Autonomous Island of Anjouan. This Policy is aligned with international best practice, including the Financial Action Task Force (FATF) Recommendations.
Compliance with this Policy is mandatory. Failure to comply may result in regulatory enforcement action against the Company, including financial penalties, suspension, or revocation of its gaming license.
2. Scope of Application
This Policy applies to:
• all players registering an account with the Company;
• the Company's Ultimate Beneficial Owners, shareholders, directors, officers and key personnel;
• employees, contractors and agents of the Company;
• third-party service providers involved in gaming, payments or player onboarding.
The Company remains fully responsible for AML/CTF compliance, including where any function described in this Policy is outsourced to a third-party service provider.
3. Legal and Regulatory Framework
This Policy is issued in compliance with:
• the AML/CTF laws and regulations applicable in Anjouan;
• directives, guidance and notices issued by Anjouan Gaming;
• international AML/CTF standards, including the FATF Recommendations;
• the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), to the extent the Company offers services to, or otherwise has obligations in respect of, persons in Canada;
• the European Union's Anti-Money Laundering Directives (in particular Directive (EU) 2015/849, as amended by Directive (EU) 2018/843 — the 5th AML Directive — and any successor instruments such as the EU AML Package / AMLR), to the extent the Company offers services to, or otherwise has obligations in respect of, persons in the European Union;
• any other applicable local, national, or supranational AML/CTF laws, regulations, or regulatory guidance relevant to the jurisdictions in which the Company operates or offers its services.
4. Core AML/CTF Principles
The Company adheres to the following principles:
• Risk-Based Approach — controls are proportionate to the identified money-laundering and terrorist-financing (ML/FT) risks.
• Transparency — funds and player activity must be traceable.
• Accountability — clear responsibility for AML compliance is established within the organization.
• Cooperation — full cooperation with Anjouan Gaming, the Anjouan Offshore Finance Authority (AOFA), and other relevant authorities.
5. Risk Assessment
5.1 Risk Identification
The Company conducts a documented AML/CTF risk assessment considering:
• player risk profiles (geography, behaviour, funding sources);
• products and services offered;
• payment methods and delivery channels;
• jurisdictions involved, including FATF-identified high-risk countries.
5.2 Risk Mitigation
Based on the identified risks, the Company:
• implements controls proportionate to those risks;
• applies Enhanced Due Diligence (EDD) where required;
• reviews and updates its risk assessment at least annually, or upon any material change to its business or risk environment.
6. Customer Due Diligence (CDD) at Registration
The Company conducts Customer Due Diligence at the point of player registration. At a minimum, the following information is collected and recorded at signup:
• full legal name;
• valid email address;
• date of birth;
• residential address.
No account may be activated unless all of the above information has been provided. An identification number (e.g., national ID or passport number) is additionally recorded where available and is required prior to any withdrawal in accordance with Section 7.
7. Enhanced Due Diligence (EDD) - Mandatory Triggers
The Company conducts Enhanced Due Diligence where any of the following occurs:
upon the player's first withdrawal request, regardless of amount;
when the player's aggregate lifetime deposits reach the applicable jurisdiction-specific threshold set out below (or the equivalent in another currency), determined by the player's country of residence:
EUR 2,000 for players in the European Union;
CAD 10,000 for players in Canada;
AUD 10,000 for players in Australia;
USD 10,000 (or the equivalent) for players in all other jurisdictions, unless a lower threshold is required by applicable local law or by the Company's payment service providers;
where elevated risk indicators or suspicious activity are identified.
The thresholds set out are reviewed and may be adjusted from time to time by the Company's Product and Anti-Fraud/Compliance teams, taking into account the player's geography, applicable local AML/CTF requirements, and the risk parameters of the Company's payment service providers.
8. Enhanced Due Diligence (EDD) — Documentation
8.1 Identity Verification (threshold-triggered EDD). Where EDD is triggered under Section 7 upon the player's first withdrawal request or upon the player's aggregate lifetime deposits reaching the applicable threshold, the player must provide, at a minimum:
• government-issued photo identification (passport, national ID card, or driving license);
• a utility bill, bank statement, or equivalent document confirming the player's residential address, dated within the last 6 months.
Additional identification documents may be requested at the Company's discretion, including a photograph of the player holding an open passport against the background of their face, or a bank card photograph showing the first six and last four digits, cardholder name and expiry date.
8.2 Source of Funds (SOF) Verification. Where the Company's risk assessment identifies elevated risk indicators, unusually large or frequent transactions, or other circumstances warranting further scrutiny, the Company will additionally require proof of source of funds. Such proof may include, but is not limited to, payslips, tax returns, bank or investment account statements, business ownership or income documentation, or other evidence reasonably demonstrating the legitimate origin of the funds used on the Website. The Company may request SOF documentation independently of, and in addition to, the identity verification requirements set out in Section 8.1.
9. Restrictions Pending Completion of EDD
Where EDD has been triggered but not yet completed to the Company's satisfaction:
• no withdrawal will be processed;
• financial activity on the account will be restricted where necessary to mitigate the identified risk.
10. Document Review and Verification Standards
Once documents are submitted, the player's account is placed in "Temporarily Approved" status pending review. The Company's KYC Team via Sumsub tool reviews submitted documents within 24 hours and notifies the player of the outcome: (i) Approved; (ii) Rejected; or (iii) further information required. Players with "Temporarily Approved" status may continue to use the platform, but their right to complete withdrawals remains limited until Approved status is confirmed.
Documents may be rejected for reasons including: the name or address on the document does not match the account details; the document is illegible, damaged, expired, or does not confirm the required information; the document is not of an accepted type; or any other reason the Company reasonably considers appropriate to its risk-based approach. Where the KYC process is unsuccessful, the reason is documented, a support ticket is created, and the ticket number and explanation are communicated to the player.
A player who fails to pass a KYC/EDD check successfully may not make further deposits or withdrawals of any amount until the matter is resolved. Under no circumstances may a player transfer funds directly to another player.
11. Ongoing Monitoring and Reporting
11.1 Transaction Monitoring
The Company implements systems to detect:
• structuring or threshold avoidance;
• rapid movement of funds;
• unusual betting patterns;
• activity involving high-risk jurisdictions.
11.2 Suspicious Activity Reports (SARs)
The Company reports suspicious activity to Anjouan Licensing Services Inc. / Anjouan Gaming within 24 hours of detection, together with full supporting documentation, using the Suspicious Activity Report format approved by Anjouan Gaming (recording, at a minimum, the date, website/brand, player username and identity details, date of birth, country, transaction date, transaction type, amount, currency and payment method).
11.3 Currency Transaction Reports (CTRs)
All transactions, or linked transactions, exceeding USD 10,000 (or the equivalent) are reported, whether suspicious or not.
12. Record Keeping
12.1 Retention Period
The Company retains AML-related records for a minimum of five (5) years, including:
• CDD and EDD documentation;
• transaction records (deposits, wagers, withdrawals);
• SARs and internal reports;
• audit and compliance records.
12.2 Accessibility
Records are stored securely and are readily available to Anjouan Gaming upon request.
13. Internal Controls and Governance
13.1 AML Policies and Procedures
The Company maintains written AML/CTF policies and procedures covering risk assessment, CDD/EDD, monitoring and reporting, record keeping, and staff training.
13.2 Compliance Officer
The Company has appointed a suitably qualified Compliance Officer responsible for AML/CTF oversight, liaison with Anjouan Gaming, and timely reporting and escalation of AML/CTF matters.
13.3 Training
All relevant staff receive AML/CTF training upon onboarding, annually thereafter, and following any material regulatory or policy change.
14. Cybersecurity and Data Protection
The Company protects the integrity and confidentiality of player data collected for KYC/AML purposes, implements appropriate technical and organizational safeguards as described in the Privacy and Cookie Policy, and reports cybersecurity incidents to Anjouan Gaming within 24 hours of discovery.
15. Independent Audits and Regulatory Inspections
The Company undergoes an independent AML audit annually, assessing policy effectiveness, regulatory compliance, and internal controls and training. Anjouan Gaming reserves the right to conduct inspections and audits of the Company at any time.
16. Player Complaints Relating to KYC/AML Decisions
Complaints relating to a KYC/EDD decision are handled in accordance with the "Player Complaints and Dispute Resolution" section of the Terms and Conditions: complaints are acknowledged within 72 hours, internal resolution is attempted within 30 calendar days, and unresolved complaints are escalated to mandatory Alternative Dispute Resolution at the Company's expense.
17. Enforcement and Consequences of Non-Compliance
Failure by a player to comply with a request made under this Policy by the applicable deadline may result in the Company confiscating winnings connected to the unverified activity, restricting or terminating the account, and returning any remaining verified balance, without prejudice to the Company's right to report the matter to Anjouan Gaming or other competent authorities.
The Company acknowledges that non-compliance with this Policy or with the AML/CTF Code of Conduct for Anjouan Internet Gaming Operators may result in financial penalties, suspension or revocation of its gaming license, public disclosure of violations, and referral to law-enforcement authorities in cases of serious or willful misconduct.
18. Continuous Improvement
The Company monitors regulatory developments, evaluates approved technological solutions (including AI-based transaction monitoring) for adoption, and participates in industry compliance initiatives.
Acknowledgment
The Company formally acknowledges and agrees to comply with the AML/CTF Code of Conduct for Anjouan Internet Gaming Operators as a condition of its license, and has adopted this KYC / AML & CTF Policy accordingly.