Anti-Money Laundering and Counter-Terrorism Financing

(AML) and Know your Customer (KYC) Policy
(last updated 08.06.2026)

 

1.      INTRODUCTION

1.1   Unless stated otherwise, all references to "we," "us," and "our" in these Terms refer to the Company, while "user", "you," and "your" refer to the individual using our Website and agreeing to this Policy.

1.2   The Company acknowledges that its services may be vulnerable to misuse for money laundering or terrorist financing activities. As a result, The Company is committed to fostering a culture of compliance by identifying, assessing, and mitigating the risks associated with ML and TF.

 

2.      DEFINITIONS OF MONEY LAUNDERING (ML) AND TERRORIST FINANCING (TF) 

2.1   Terrorist Financing (TF)
Terrorist financing refers to any action involving:

·     The provision or accumulation of financial resources by an individual who either intends or negligently disregards the possibility that such funds will be utilized to support or carry out terrorist activities.

·     Participation in any financial arrangement that grants access to money or assets for another party while being aware of or having reasonable grounds to suspect that these resources might contribute to terrorism.

2.2   Money Laundering (ML)
Money laundering encompasses:

·     The handling, transfer, possession, or distribution of funds or assets—through any method or channel—with the purpose of disguising their origins, despite knowing, believing, or recklessly ignoring that they were acquired directly or indirectly through illicit means.

·     Engaging in or facilitating financial transactions that enable another individual to obtain, hold, use, or manage illicitly sourced property while being aware or suspecting its criminal origin.

2.3   Stages of Money Laundering
The money laundering process typically unfolds in three phases:

·     Placement: Illegally acquired funds enter the financial system, often through deposits or conversion into monetary instruments.

·     Layering: The origins of the funds are deliberately concealed by conducting multiple transactions, such as transfers or conversions.

·     Integration: The "cleaned" money is reinvested or withdrawn in a way that gives it the appearance of legitimacy, such as through legal investments or structured withdrawals.

 

3.      POLICY STATEMENT AND OBJECTIVES

3.1 The Company strictly prohibits the use of its Services for any illegal purposes, including money laundering (ML), terrorist financing (TF), or violations of sanctions. To prevent such activities, The Company is committed to:

·        Conducting and regularly updating a risk assessment related to ML and TF, which serves as the foundation of the AML Program. This assessment considers risks associated with users, transactions, products, payment methods, and geographic locations.

·        Implementing a comprehensive AML Program, including written policies, procedures, and controls designed to identify, assess, and mitigate ML and TF risks in compliance with regulatory requirements.

·        Appointing a senior manager responsible for overseeing the implementation of the AML Program and related policies, procedures, and controls.

·        Providing employees with continuous training and education on AML and compliance matters.

·        Engaging in independent reviews, conducting ongoing monitoring, and performing internal audits to assess the effectiveness of the AML Program, policies, procedures, and controls.

·        Cooperating fully with AML regulatory authorities and other relevant institutions.

·        Continuously improving this Policy and the AML Program through regular reviews, ensuring compliance with legal updates, best practices, regulatory guidance, and audit findings.

3.2 The primary aim of this AML and KYC Policy is to define the key procedures, systems, and controls that The Company has implemented to detect and reduce the risks of ML and TF within its operations.

 

4.      SECURITY AND MONITORING

4.1   Robust monitoring practices are crucial for any gaming business to maintain security across all operational aspects, including physical locations, equipment, personnel, communications, and financial transactions. To uphold these security standards, the Company will implement a comprehensive set of protective measures and procedures.

4.2   The Company employs call recording technology to enhance operational efficiency and security. This system provides several key benefits, such as:

·        Improving staff training and professional development;

·        Ensuring precise documentation of bets, transaction times, and financial records;

·        Safeguarding user interests while preserving the Company’s reputation;

·        Strengthening monitoring protocols to detect and prevent potential collusion between employees and users.

4.3   Given the importance of data protection and the security of software and hardware—especially in a Non-Face-to-Face transaction environment—The Company will follow a strict policy of "Encrypt whatever can be encrypted." Access to shared drives will be strictly controlled, monitored, and, where necessary, password-protected. Secure data storage and backup procedures are in place to ensure that user data remains protected from unauthorized access and to prevent data loss.

5.      CUSTOMER RISK ASSESSMENT

5.1   At registration, the Company conducts an initial risk assessment of each customer to determine their Money Laundering (ML) and Terrorist Financing (TF) risk level. This assessment, based on information collected during registration, is updated regularly as new data becomes available. Customers are classified as Low, Medium, or High risk, which determines the degree of monitoring and due diligence applied.

5.2.   The risk assessment considers:

·     Individual Status – whether the customer is a Politically Exposed Person (PEP) or appears on sanctions lists.

·     Geographical Risk – the risk level associated with the customer’s country of residence.

·     Behavioral Analysis – gambling and transaction patterns that may indicate ML or TF.

·     Payment Methods – risks linked to the methods used for deposits and withdrawals.

·     Fraud Indicators – signs of fraud or other suspicious activities.

Customers who are considered High Risk will need to undergo EDD.

High-risk customers are subject to Enhanced Due Diligence (EDD). The Company applies a risk-based approach to monitor customers’ typical transaction volumes and amounts. If unusual or suspicious activity is detected, further checks or EDD may be performed to ensure the activity aligns with the customer’s profile and to mitigate potential risks.

5.3.   Risk Score Calculation

This procedure aims to identify minor instances of potential ML/FT activity that, while not suspicious in isolation, may indicate risk when combined with other behaviours.

The internal CMS system assesses players across multiple factors, assigning a score to each. These scores are aggregated to produce a total risk score, with higher negative scores reflecting a greater level of risk.

Indicator	Description	Score
Individual status
PEP	A customer considered to be PEP	50
Adverse media	A customer was mentioned in negative news or information the company discovered from various sources	50
Sanctions/blacklist	A customer is under international sanctions/blacklists	50
Geographical location
Not at home	A customer whose IP location is different from their registered address	20
High-risk country resident	A customer resides in a High-risk country	30
Gambling behaviour
Large sums no play	A customer depositing large sums, then places minimal stake bets, then withdrawing all their funds	50
Large sums big losses	A customer depositing large amounts and repeatedly losing large amounts as if the loss is of no consequence	50
Low odds betting	A customer repeatedly placing short odds (such as red/black on roulette or repetitive betting on favourites) bets	25
Big changes in money	Dramatic changes in terms of volume and size of player deposits or staking activity	20
Several gaming accounts	A customer is trying to register several gaming accounts	30
Transactional behaviour
Smurfing	A customer making multiple deposits or withdrawals of small amounts without no objective reasons	30
Spending above wages	A customers spend is outside of their affordability	20
No withdrawals	Player has never requested a withdrawal	-20
Withdrawal without playing	Money is deposited by a customer or held over a period and withdrawn by the customer without being used for gambling	30
Payment methods the player is using
Card switching	A customer opening an account and registering several different cards and making transfers between them	20
High risk payment methods	A customer uses high-risk payment methods	30
Fraud red flags a customer triggered
VPN	Customer used a VPN	30

 

Once the score is calculated, a risk level is assigned:

CMM Score	Risk Category
0-20	Low
21 - 40	Medium
41 - and higher	High

Due to certain technical and practical constraints, not all factors can be incorporated into the automated calculation. These risks are instead managed through alternative monitoring measures. For example, we detect VPN use and multi-accounting at registration, maintain separate alerts for players using cards registered under different names, and manually review all withdrawals prior to approval and payment.

5.4.   Customer Due Diligence level

The level of customer due diligence (CDD) conducted on a player will depend on the risk score assigned to the player as follows:

 

	Low	Med	High
Verify ID and address with docs	X	X	X
Collect additional personal details	X	X	X
Collect Source of Funds/ Wealth info		X	X (with documentation)
Ongoing monitoring	X	X	X (Enhanced)
Additional measures to address any other risk identified			X
Report suspected cases of ML/FT	X	X	X

 

The frequency of customer reviews is determined by the assessed risk level, taking into account factors such as geographic location, transaction patterns, and source of funds. High-risk customers, such as those from higher-risk regions or displaying suspicious activity, are monitored more frequently. Medium-risk customers are reviewed on a regular periodic basis, while low-risk customers are assessed less often. The Company adjusts review frequencies in line with regulatory requirements and updates them whenever there are significant changes in a customer’s risk profile.

6.      EMPLOYEE ROLES AND COMPLIANCE OBLIGATIONS

6.1   The Company has designated a senior manager as the Compliance Officer, tasked with overseeing the development, implementation, and enforcement of anti-money laundering (AML) measures. This role ensures adherence to relevant regulations and the Company’s AML framework, including this Policy. The Compliance Officer's primary duties include:

·        Designing, implementing, and assessing AML strategies;

·        Engaging with key stakeholders to stay informed on emerging AML trends and industry best practices;

·        Managing and regularly updating AML policies and procedures;

·        Evaluating regulatory changes and business developments to ensure compliance;

·        Identifying high-risk scenarios and recommending appropriate safeguards;

·        Conducting investigations and reporting suspicious activities;

·        Preparing and delivering compliance reports to senior management and Director.

6.2   All employees, directors, and officers, regardless of their position within the Company, must adhere to this Policy and actively contribute to identifying and preventing money laundering (ML) and terrorist financing (TF). If an employee suspects or has reason to believe that a transaction, potential transaction, or any other activity may be linked to criminal activity, they are required to report it immediately to the relevant manager. Failure to do so may result in disciplinary measures.

6.3   The Company is dedicated to equipping all employees with the necessary knowledge and training to identify and report suspicious activities effectively. To ensure continued compliance, staff will receive ongoing training on ML and TF risks and regulatory obligations, with refresher courses conducted at least once per year.

The AML training program covers the following core topics:

·        Overview of applicable AML/CTF laws and regulatory obligations (including Tobique jurisdiction-specific requirements)

·        Key money laundering (ML) and terrorist financing (TF) typologies and red flags

·        Customer due diligence (CDD), enhanced due diligence (EDD), and ongoing monitoring procedures

·        Procedures for identifying and reporting suspicious transactions (STRs)

·        Recordkeeping and data protection requirements

·        Sanctions compliance and PEP identification

·        Use of AML-related tools and systems, including screening software

·        Internal escalation processes and the role of the Compliance Officer

Covered Roles and Departments

The training program is tailored to the responsibilities of different employee groups. The following roles are covered:

·        Front-line staff and customer-facing teams: Trained to recognize red flags and apply CDD/EDD procedures.

·        Operations and payments personnel: Instructed on transaction monitoring, sanctions screening, and handling suspicious activities.

·        Compliance and risk management staff: Receive in-depth training on regulatory developments, internal controls, reporting obligations, and case analysis.

·        Senior management and director: Provided with strategic AML/CTF training to support a top-down culture of compliance and meet governance responsibilities.

Documentation and Monitoring
The Company maintains detailed records of all training sessions, including:

·        Date of training

·        List of attendees and their roles

·        Content and materials used

·        Assessment results, where applicable

6.4   As part of its commitment to mitigating ML and TF risks, The Company upholds high recruitment standards, including conducting background checks on new employees.

 

7.      RISK APPETITE STATEMENT

7.1   The Risk Appetite Statement (the "Statement") defines the boundaries within which the Company shall operate to maintain compliance with the Tobique Gaming Act 2023 and the Tobique Gaming Commission (TGC) Remote Gambling Code of Practice.

7.2   This Statement applies to all employees, directors, and officers of the Company, and serves as a mandatory guide for the Compliance Officer in the execution of Customer Due Diligence (CDD) and transaction monitoring.

7.3   The Company classifies its risk tolerance into four distinct levels to provide clear operational guardrails, aligned with the Customer Monitoring Mechanism (CMM) and jurisdictional restrictions:

7.3.1        Zero Tolerance: The Company maintains zero appetite for any activity that involves intentional regulatory breach, sanctioned persons, or illegal conduct. This includes the onboarding of minors, persons in restricted jurisdictions (e.g., USA, UK, Russia, FATF blacklisted countries), or the use of anonymity-enhancing tools. Any identified risks in this category shall result in immediate account termination and reporting.

7.3.2        Low Tolerance: The Company seeks to avoid risk and uncertainty. Engagement with the customers categorized as "High Risk" with CMM scores of 41 or higher, or those meeting the EUR 10,000 transaction threshold—requires the highest level of Enhanced Due Diligence (EDD), Source of Wealth (SOW) verification, and documented MLRO approval.

7.3.3        Moderate Tolerance: The Company prefers options with low residual risk and established controls. These risks involve customers categorized as "Medium Risk" (CMM scores 21–40) and are managed through the  Customer Due Diligence (CDD), including verification of ID and address, and periodic monitoring every 24 months.

7.3.4        Strategic Tolerance: The Company may accept higher risk for innovation or growth purposes, provided robust mitigation controls are in place. This primarily involves "Low Risk" customers (CMM scores 0–20) who are subject to routine automated monitoring and standard SDD protocols.

7.4   The following Key Risk Indicators (KRIs) shall be monitored continuously. Breaches of these thresholds require immediate escalation to the Compliance Officer.

 

Risk Indicator	Tolerance Limit	Policy Action
CMM Risk Score	Score ≥ 41 (High)	Mandatory EDD and Compliance Officer review.
Individual Deposit Limit	≥ EUR 2,000	Immediate identity and address verification.
Cumulative Volume (30 days)	≥ EUR 10,000	Mandatory SOW/SOF documentation and EDD.
Verification Status	"Temporarily Approved"	Restriction from making withdrawals until final review.
Prohibited IPs	1 attempt	Immediate geo-blocking and account flagging.

 

7.5   The Company’s Risk Appetite is operationalized through the CMM scoring logic defined in Section 6.0 of the AML Policy.

7.6   Any user identified with a CMM score reflecting "High Risk" (41+) resides at the absolute limit of the Company’s appetite. Continued platform access for these users is conditional upon successful verification of legitimate Source of Funds and Source of Wealth.

 

8.      KYC POLICY AND DUE DILIGENCE

8.1   The Company adheres strictly to "Know Your Customer" (KYC) protocols to combat financial crimes, including money laundering, by implementing rigorous client identification and due diligence measures.

8.2   The Company reserves the right to request KYC documentation at any time to confirm a user's identity and location. Until the verification process is satisfactorily completed, access to services, transactions, and withdrawals may be restricted at the Company's sole discretion, in alignment with applicable legal requirements.

8.3   A risk-based approach is applied to all users, incorporating stringent due diligence procedures and continuous transaction monitoring. In compliance with anti-money laundering regulations, the Company implements a three-tiered due diligence framework, adjusted according to transaction type, risk level, and user profile:

·        Simplified Due Diligence (SDD): Applied to low-risk transactions below designated thresholds, typically conducted during account registration.

·        Customer Due Diligence (CDD): The standard verification process required in most cases, commonly triggered when a user makes a deposit.

·        Enhanced Due Diligence (EDD): Used for high-risk users, large transactions, or unusual circumstances requiring additional scrutiny.

8.4   By applying a risk-based approach, the level of due diligence is adjusted accordingly—the higher the risk of money laundering or terrorist financing, the more extensive the verification process.

8.5   The following categories of individuals and entities are prohibited from using the Company's services:

·        Minors;

·        Beneficial owners (whether disclosed or undisclosed) or agents acting on behalf of users;

·        Non-individual entities, such as companies or trusts;

·        Persons subject to sanctions;

·        Individuals residing in Restricted Jurisdictions.

8.6   Restricted jurisdictions and geoblocking
When a User registers an account on the Website, his or her place of residence/domicile (hereinafter the "Jurisdiction") must be considered as a matter of priority. At first, the Company checks whether the jurisdiction is on the European Commission's list of "high-risk third countries with strategic deficiencies" (see "sources"). Then, the Company checks whether or not the jurisdiction is presented in the list of "high-risk and other monitored jurisdictions", presented by FATF. Furthermore, the Company conducts its own monitoring of the jurisdictions based on the following parameters:

·         Legal environment.

·         Political environment.

·         A country's economic structure.

·         Cultural factors and the nature of civil society.

·         Sources, location and concentration of criminal activity (if any).

8.7   Restricted jurisdictions are included:
- Afghanistan
- Canadian Province of New Brunswick

- China

- Cuba

- Central African Republic

- Democratic Republic of Congo

- Haiti

- Iran

- Iraq

- Israel

- Libya

- Myanmar

- North Korea

- Russia

- Somalia

- South Sudan

- Syria

- UK

- USA

- Yemen

- Venezuela

- FATF black listed countries
https://www.fatf-gafi.org/en/countries.html#high-risk

 

8.8   Required Documentation and Information
Depending on the type of verification process, The Company may request the following types of documents and details from users:

8.8.1        Basic Identification Information:

·         Full legal name

·         Date of birth

·         Permanent residential address

·         Official identification number

8.9   User Identity Verification:

·     When a user deposits EUR 2,000 or more within a specified timeframe, or in other cases deemed necessary, The Company will verify the user's identity using third-party verification services, internal data, or a combination of both.

·     This verification process may involve cross-checking the user's KYC information with a valid passport, driver's license, or national ID.

·     Pending withdrawals may be placed on hold until the requested KYC information is successfully verified or updated.

8.9.1        Depending on the verification process, The Company may request the following documents:

·         A copy or a photo of the user's identification document;

·         A photo of the payment card used or intended to be used in making deposits on the Website. It is important that the name of the cardholder must match the name of the user who passes the verification. CVV code and payment card number (except first six and last four digits) may be hidden or covered. The cardholder's name must not be hidden or covered in any way;

·         A photo of the user holding the documents required for the verification process (may be with the requested information, written by hand (the e-mail of the user, used when registering an account; the date of the photo request and the confirmation code);

·         If applicable, include a bank statement, a letter from User’s duty station or place of employment, and a tax bill;

·         If applicable, User’s address confirmation. It may be a utility bill, a phone bill, or other documents that, in accordance with the jurisdiction's legal and regulatory requirements, are sufficient to confirm the User's address;

·         Any other documents or information that the situation may require.

8.9.2        Once the required documents are uploaded, the user will receive a "Temporarily Approved" status. At this stage, the documents are under review by The Company's KYC Team, which will assess them within 24 hours and notify the user of the outcome via email. The possible outcomes are:

·      Approved – Verification is successfully completed.

·      Rejected – The documents do not meet the verification requirements.

·      More Information Needed – Additional details or documents are required (status remains unchanged).

8.9.3        Users with a "Temporarily Approved" status can access the platform’s services but are restricted from making withdrawals.

8.9.4        After reviewing the documents, The Company will make a final decision regarding verification. If the KYC process is unsuccessful, the reason will be documented, and a support ticket will be created. The user will receive a ticket number along with an explanation of the decision.

8.9.5        Users who fail the KYC verification process will be restricted from making further deposits or withdrawals.

8.9.6        If a user successfully passes the KYC process, any withdrawal request will undergo both automated and manual verification to ensure the funds were legitimately obtained through platform activity.

8.10   Additional verification

8.10.1     The Company may implement additional verification processes in the following circumstances:

a) The user meets the definition of a Politically Exposed Person (PEP).
A politically exposed person is defined as a natural person who is or has been entrusted with prominent public functions, which include the following: (a) heads of government, heads of state, ministers, and deputy or assistant ministers; (b) members of parliament or similar legislative bodies; (c) members of political party governing bodies; (d) members of supreme courts, constitutional courts, or other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances; (e) members of courts of auditors or central bank boards; (f) ambassadors, chargés d'affaires, and high-ranking officers in the armed forces; (g) members of State-owned enterprise administrative, management, or supervisory bodies; and (h) directors, deputy directors, and members of an international organization's board or equivalent function.

b) If the User's country of residence is defined by the European Commission as a "third country with strategic deficiencies" or is on the FATF's list of "high-risk and other monitored jurisdictions";

c) In other cases, when additional verification is required by law or at the request of authorities, financial institutions, etc.

8.10.2     In addition to the standard verification, when applying additional verification, the Company requires to submit the document(s) or data on the source of the user's income in accordance with the jurisdiction's legal and regulatory requirements when using additional verification. In the event of additional verification, the final approval on the verification will be done by Senior management of the Company.

8.10.3     For the purposes of this Policy, the Company reserves the right to collect additional user identification data. Furthermore, if a) a user refuses to pass verification; and/or b) the Company has reasonable grounds to suspect that a user is using the Company for illegal purposes and the user does not provide evidence to the contrary, the Company may inform appropriate government authorities on such case. Additionally, the Company may suspend the User's account until the user passes a verification process or provides the document(s) or information requested by the Company.

8.11   Where technically possible, The Company will prevent onboarding, block, or suspend users who meet any of the following criteria:

·      Failure to Provide Identification – Users who do not submit the required identification documents or fail identity verification.

·      Submission of Fraudulent Documents – Users who provide fake, altered, or otherwise fraudulent identification materials.

·      Concealment of Identity or Location – Users who attempt to mask their real identity or geographical location.

·      Restricted Jurisdiction Users – Individuals who are from or currently located in a jurisdiction where The Company does not offer services.

·      Sanctioned Individuals – Users appearing on U.S., EU, or other international sanctions and watch lists.

·      Multiple Accounts – Users attempting to operate or create duplicate accounts on the platform.

 

9.      ENHANCED DUE DILIGENCE

9.1   The Customer Due Diligence (CDD) process outlines the steps taken to verify user identities, specifying the circumstances and timeframes in which verification is required. It also defines scenarios where Enhanced Due Diligence (EDD) must be conducted for higher-risk users.

9.2   The Company applies Enhanced Due Diligence (EDD) measures for users engaging in transactions that exceed EUR 10,000 within a 30-day period, or in cases where transactions exhibit unusual patterns, involve high-risk jurisdictions, or relate to politically exposed persons (PEPs).

9.3   For customers deemed high-risk or becoming high-risk, the Company undertakes EDD measures, which may include:

 

·             Re-verifying the customer's identity (repeated CDD);

·             Establishing the legitimacy of the customer's wealth through documentation such as:

o   Salary income or company profit (payslips, employer letters, or audited accounts);

o   Sale or liquidation of financial instruments (Certified sale contracts or statements, accountant letter, etc.);

o   Sale of property (Certified copy of sale contract, letter from solicitor or estate agent);

o   Inheritance (Certified copy of will including the value of inheritance);

o   Sale of the company (Certified contracts, media articles, certified letter from accountant or solicitor);

·             Confirming that the source of the customer's funds does not originate from criminal activities;

·             Ensuring deposits come from identifiable payment methods by requesting bank or account statements;

·             Conducting increased continuous monitoring of the business relationship;

·             Investigating suspicious transactions and monitoring the underlying business relationship to assess money laundering and terrorist financing risks.

 

The primary aim of EDD on transactions is to ensure the transparency of payment flows. Each transaction's origin and destination must be traceable back to an account.

 

9.4   While low and medium-risk users are primarily monitored through internal compliance measures, The Company reserves the right to request EDD-level documentation if their activity exhibits ML/TF risk indicators or if further verification is deemed necessary.

9.5   Definitions:

Source of Funds: Refers to the origin of the specific funds used for deposits on the Company's website. This involves verifying more than just the bank or financial institution; it requires substantive information that establishes the funds' origin and acquisition method.

 

Source of Wealth: Refers to the origin of the customer's total assets. The Company must obtain information indicating the volume of wealth reasonably expected for the client and providing a clear picture of how this wealth was acquired.

 

10.  ONGOING MONITORING

10.1                   The Company actively monitors user activities to detect any potential money laundering (ML), terrorist financing (TF), sanctions violations, or other illicit activities.
This includes:

I. Transaction Screening for Restricted Jurisdictions
The Company employs a combination of automated and manual monitoring tools to detect potential money laundering and terrorist financing activities. Automated systems utilize AI-driven risk assessment models to flag unusual transactions based on pre-defined thresholds and behavioral anomalies. Manual reviews are conducted by the Compliance Team for flagged transactions and high-risk users.
The effectiveness of monitoring systems is evaluated through regular internal audits and independent third-party reviews, conducted at least annually.

II. Sanctions & Politically Exposed Persons (PEP) Monitoring
When a user is identified as a Politically Exposed Person (PEP), the Director is notified and determines whether to proceed with the business relationship. If approved, the user is classified as high risk, and enhanced due diligence (EDD) measures are implemented to ensure strict compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations.

III. Detection of Unusual Transactions

The Company actively monitors transaction patterns, volumes, and frequencies to identify irregular or high-risk activity. Complex or suspicious transactions are documented, reviewed, and escalated to senior management for further assessment and appropriate action.
The Company applies the following triggers for enhanced review:

·        Transactions exceeding EUR 2,000 that deviate from a user’s typical transaction behavior;

·        Rapid movement of funds between multiple accounts without clear justification;

·        Deposits or withdrawals involving high-risk jurisdictions or third-party payments;

·        Large cash deposits followed by immediate withdrawals or transfers.
Upon detection of a suspicious transaction, the Compliance Team conducts a detailed review, and if necessary, reports the activity to the Tobique Gaming Commission and relevant Financial Intelligence Units (FIUs).

IV. Prohibition of Anonymity Tools
The use of tumblers, and other anonymity-enhancing technologies is strictly forbidden. If such tools are detected, the Company will block them, and any related transactions will undergo a case-by-case review to determine potential risks.
V. Withdrawal-Based KYC Verification
Withdrawals may be temporarily suspended until additional customer due diligence (CDD) is performed. This precaution is triggered when withdrawal amounts exceed designated risk thresholds, requiring further review.
VI. Prevention of Ban Evasion
To maintain security and compliance, each user is permitted to have only one account, as outlined in the Terms of Service. Automated detection systems are in place to identify and prevent users from creating multiple accounts under different identities.
VII. Location & Time Zone Monitoring
The Company examines device location data to detect attempts to disguise geographic locations. Accounts suspected of using VPNs, proxy services, or other methods to bypass jurisdictional restrictions may be temporarily suspended for further investigation.
VIII. Oversight of Third-Party Service Providers
The Company routinely assesses third-party vendors to ensure their compliance with ML/TF risk management protocols. Periodic evaluations are conducted to determine whether additional safeguards are needed or if corrective measures should be implemented.
IX. Advancements in Compliance Technologies
The Company continuously explores innovative compliance solutions, including blockchain-based fraud detection and on-chain KYC technologies, to enhance security measures and meet evolving regulatory requirements.

 

9.2   Users are encouraged to submit additional documentation or information to challenge any suspensions, restrictions, or flagged transactions as part of The Company’s ongoing monitoring and due diligence process.

9.3   The company implements a robust and risk-based approach to the periodic review of client dossiers. These reviews are an integral component of our ongoing monitoring process and are designed to ensure that customer information remains accurate, up-to-date, and relevant to the assessed level of risk.

9.3.1.      Frequency of Reviews
The frequency of periodic client dossier reviews is determined based on the customer’s risk classification:

·        High-Risk Clients: Reviewed annually (every 12 months)

·        Medium-Risk Clients: Reviewed biennially (every 24 months)

·        Low-Risk Clients: Reviewed every 36 months or upon trigger events

Trigger events that may prompt an earlier review include, but are not limited to:

·        Changes in the customer’s identification information

·        Unusual or suspicious transaction patterns

·        Regulatory updates requiring enhanced scrutiny

·        Changes in the customer’s risk profile or business activity

2. Scope of Review

Each periodic review includes the following steps:

·        Verification of identity documents to ensure validity and authenticity

·        Assessment of the client’s source of funds and source of wealth, particularly for high-risk clients

·        Review of transaction history to identify patterns or activities inconsistent with the customer’s known profile

·        Re-evaluation of the client’s risk rating, adjusting it as necessary based on new information or behavioral patterns

·        Confirmation of PEP or sanctions status through updated screening tools

10.      ADVERSE MEDIA AND NEGATIVE NEWS SCREENING

 

10.1.        In line with our risk-based approach and ongoing monitoring obligations under the Tobique Gaming Authority regulations, the Company performs continuous screening for adverse media and negative news related to its customers and their beneficial owners.

10.2.        Ongoing Monitoring Process

We conduct adverse media screening as part of both the onboarding process and ongoing customer due diligence. This includes the identification of:

·        Negative or adverse media coverage

·        Reputational risks

·        Public allegations of financial crimes (e.g., fraud, corruption, money laundering)

·        Involvement in criminal investigations or legal proceedings

10.3.        Screening Tools Used

To ensure comprehensive and up-to-date monitoring, we utilize third-party compliance tools that include:

·        AI-powered media monitoring platforms

·        Global sanctions and watchlist databases

·        Politically Exposed Persons (PEP) screening tools

·        Structured and unstructured data sources, including international news, regulatory publications, and open-source intelligence

10.4.         Escalation and Review

When adverse media or negative news is detected, the Compliance Officer is notified immediately. A formal review is conducted to assess the credibility and relevance of the information.

 

11.     REPORTING

11.1.        If there is suspicion that a user is involved in money laundering or terrorist financing (ML/FT), staff must submit an internal report to the Compliance Officer. When unusual activity is detected, an unusual activity report will be prepared and reviewed by the Compliance Officer (or their delegate) to assess whether a suspicious transaction report needs to be filed.

11.2.        If a user is suspected of engaging in money laundering or terrorist financing activities, the Company follows a structured escalation process:

 

·         Transaction Review & Temporary Account Suspension – The suspicious transaction is flagged, and the user’s account may be temporarily restricted pending further investigation.

·         Enhanced Due Diligence (EDD) Measures – The user is required to submit additional documents, such as proof of source of funds and wealth verification.

·         Filing a Suspicious Transaction Report (STR) – If the suspicion is substantiated, a report is filed with the Tobique Gaming Commission and relevant FIUs.

·         Account Closure & Funds Freezing – If the user fails to provide satisfactory explanations or if criminal activity is confirmed, the account may be permanently closed, and funds may be frozen in accordance with regulatory requirements.

·         Right to Appeal – Users whose accounts are restricted may request a review, providing additional documentation to contest the decision. The final determination is made by the Senior Compliance Officer.

11.3.        The Company will file a Suspicious Matter Report (SMR) with the Tobique Gaming Commission as required by applicable law in cases where:

·      there are reasonable grounds to suspect that a User is misrepresenting their identity;

·      there are reasonable grounds to believe that our Services are being used in connection with money laundering (ML), terrorist financing (TF), or other criminal activities; and/or

·      a transaction appears to lack a legitimate economic purpose.

11.4.        Additionally, if a User is identified on a sanctions list or linked to ML, TF, or other illicit activities, we will submit a report to the relevant Financial Intelligence Unit (FIU).

11.5.        The Company will also maintain comprehensive records to ensure compliance with all applicable ML/TF regulatory requirements.

12.     RECORD KEEPING PERIOD

12.1.        For a period of 5 (five) years, the Company may keep a record of the verification data of the Website's Users, as well as the transaction data (the history of the transactions and their supporting evidence) in easily accessible form. Please refer to the Privacy Policy for more information on the storage of personal data of Website users.

13.     REFERENCES

Here you can find the source list (but not limited to) for this Policy. Additional legislation or documents may be applied.

1.      The Forty Recommendations and Special Recommendations on Terrorism Financing ("FATF Recommendations");

2.      Risk-based approach guidance for the casinos (RBA for Casinos), issued by FATF;

3.      Directive 2015/849 of the European Union and Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing;

4.      Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies;

5.      REGULATIONS CONCERNING ANTI-MONEY LAUNDERING AND COUNTER TERRORISM FINANCING enacted by the Tobique Gaming Commission on April 5, 2024 pursuant to Section 22 of the TOBIQUE GAMING ACT 2023.

6.      AML CODE OF PRACTICE FOR REMOTE GAMING LICENSE HOLDERS enacted by the Tobique Gaming Commission on April 5, 2024 pursuant to Section 22 of the TOBIQUE GAMING ACT 2023

7.      FATF list of High-risk and other monitored jurisdictions: http://www.fatf-gafi.org/countries/#high-risk

 

Document type:	Policy
Version:	1.0
Version Date:	08.06.2026
Approved by:	Andreas Bitis, Director
Owner of the Document:	Oleksandr Tasmaly, Compliance Officer