AML & KYC Policy

General Provisions

As a company duly registered and licensed for the provision of online gaming services, we are fully committed to applying measures to prevent Money Laundering and Combatting Terrorism Financing. We are also committed to our social duty in preventing our systems from being used as a tool for crime.

We will endeavor to stay updated with developments in prevention measures in order to protect the organization, its operations and reputation.

Our policies and procedures were built and continue to be updated to observe the laws relevant to our operations.

Laws and Regulations

As a licensed igaming operator we are subject to the supervisory Authority for our service.

We are required to comply with all applicable laws and regulations within the jurisdiction of our operation, including identification for services, identification when rendering services, and the reporting of unusual transactions.

We are required as a service provider of online games of chance to have in place adequate practices and procedures to prevent our systems from activity facilitating money laundering and the funding of terrorist and criminal activities.

Players Onboarding and Customer Journey

The customer journey begins when a player registers an account and provides the information required to create and maintain the customer relationship. Customer Due Diligence is performed when a customer reaches the applicable cumulative deposit threshold, requests a first withdrawal, or where suspicious activity is identified, regardless of the transaction amount.

The Company may request additional information or documentation to verify a customer's identity, activity, or source of funds and may apply Enhanced Due Diligence measures where necessary.

Following successful verification, customer accounts remain subject to ongoing monitoring. The Company reviews customer activity and transactions and may request further information or documentation where appropriate.

Further details regarding customer verification, documents and information collected, Enhanced Due Diligence, PEP and sanctions screening, restricted jurisdictions, and ongoing transaction monitoring are set out in the sections below.

Customer Due Diligence

The Company will apply appropriate Customer Due Diligence (“CDD”) measures and customer verification procedures as required by law, including utilizing identifiers. CDD checks as part of the player onboarding and represents a continuous process during the customer’s journey.

Player Identification

Operators must verify the identity of all players upon first withdrawal request, regardless of amount or when total cumulative deposits reach US $10,000 or equivalent.

Required information includes:

• Full legal name
• Date of birth
• Nationality
• Full residential address
• Government-issued photo ID

Verification

Collected customer information is being processed by utilising prescribed methods and verification solutions.

Verification is conducted through:

• Certified copies of identification documents
• Independent electronic verification services (3rd parties)
• Official utility bills or bank statements for address confirmation.

Threshold for Verification

The CDD process is triggered upon specific conditions, as prescribed by the KYC-AML Code of Conduct for Anjouan Internet Gaming Operators.

These conditions are:

• Cumulative deposits reach $10,000 USD or equivalent
• On first withdrawal regardless of amount
• Suspicious activity is detected, regardless of the transaction amount

Enhanced Due Diligence

At any time, when a customer’s risk profile changes based upon any number of ‘red flags’, the Company will conduct Enhanced Due Diligence (“EDD”), including verification based on personal documents, and publicly held data, privilege information from other operators and sources, financial or corporate data, and third-party data providers.

The EDD is required for:

• Politically exposed persons (PEPs) and their family members or associates
• Players from high-risk jurisdictions identified by FATF
• Complex or unusually large transactions with no apparent economic purpose

The EDD checks include obtaining additional information regarding the customer's Source of Funds (“SOF”) and Source of Wealth (“SOW”), requesting supporting documentation, conducting enhanced screening and adverse media checks, and applying increased monitoring of account activity and transactions.

PEP & Sanctions

What is a Politically Exposed Person (PEP)?

A Politically Exposed Person ("PEP") is an individual who is or has been entrusted with a prominent public function, including but not limited to heads of state, senior government officials, members of parliament, senior judicial or military officials, executives of state-owned enterprises, and senior officials of international organizations. Immediate family members and close associates of such persons may also be considered PEPs.

In accordance with applicable Anti-Money Laundering and Counter-Terrorist Financing requirements, the Company applies Enhanced Due Diligence measures, (refer to Enhance Due Diligence item above), to customers identified as PEPs. This may include obtaining additional information regarding identity, source of funds, source of wealth, and ongoing monitoring of account activity.

Enhanced Due Diligence check is not only required for PEPs, but also their family members or associates.

What are Sanctions?

Sanctions are restrictive measures imposed by governments or international organizations on certain individuals, entities, countries, or activities.

As part of its AML and CTF obligations, the Company screens customers against applicable sanctions lists and may restrict or refuse services where required by applicable law or regulatory requirements.

Ongoing Transaction Monitoring

The Company has a duty to monitor all customer transactions and relationships in accordance with industry best practice, international recommendations and guidelines.

Any suspicious transactions or circumstances potentially related to Money Laundering and Terrorist Financing will be reported to the relevant law enforcement authority without delay.

Monitoring system shall monitor and analyze player transactions for:

• Unusual patterns (e.g., apparent fluctuation in usual depositing & unexpected gameplay behaviour)
• Complex or unusually large transactions with no apparent economic purpose
• Transactions involving high-risk jurisdictions

Suspicious transactions shall be reported to Anjouan Licensing Services Inc. within 24 hours of detection. Suspicious Activity Report (“SAR”) will Include detailed descriptions of the activity, player information, and supporting evidence.

Reporting requirements also include Currency Transaction Reports (“CTR”), which are reportable events of transactions or groups of linked transactions exceeding $10,000 USD or equivalent. CTRs are also reportable to Anjouan Licensing Services Inc., even if no suspicion arises.

Documents and Information Collected

In order to validate and accept the information submitted by a customer, all documents provided must be valid, current, and fully visible (in case of picture). The Company may collect and verify information relating to a customer's identity, age, residential address, payment methods, Source of Funds (SOF), Source of Wealth (SOW), and any other information required to satisfy its regulatory obligations.

Acceptable Verification Documents

For identity and date of birth verification:

• Valid passport
• National identity card
• Driving licence
• Residence permit or other government-issued photo identification

For proof of address:

• Utility bill
• Bank or credit card statement
• Government-issued correspondence
• Tax, municipal, or residency document

Proof of address documents must display the customer's full name and residential address and, unless otherwise approved by the Company, should be dated within the last three (3) months.

Collected data and information are being retained as per Record Keeping item in this policy.

Record Keeping

As per the regulatory requirements, the Company reserves right to retain the following records for a period of minimum five (5) years:

• Player identification and verification documents
• Transaction logs, including deposits, wagers, and withdrawals
• Suspicious activity reports (SARs) and all related information
• Internal audit and compliance reports

Restricted Jurisdictions

The following jurisdictions are restricted:

Australia, Austria, Comoros, France, Germany, Netherlands, Spain, United Kingdom, USA, Belgium, Czech Republic, Estonia, France, Guernsey, Netherlands, Isle of Man, Algeria, Angola, Côte d'Ivoire, Kenya, Libya, Niger, Afghanistan, Belarus, Burundi, Central African Republic, Curacao, North Korea, Congo, Guinea, Guinea-Bissau, Haiti, Iran, Jersey, Mali, Malta, Myanmar, Namibia, Nicaragua, Russia, Somalia, South Sudan, Sudan, Syria, Virgin Islands, Yemen and all FATF Blacklisted countries