AML Policy

1. Introduction

The owner of this site ("Company", "we", "us") is committed to combating money laundering and terrorist financing. This Anti-Money Laundering (AML) Policy outlines our procedures and practices for complying with relevant laws and regulations. We are dedicated to preventing our Platform from being used for illegal activities and protecting the integrity of the gaming industry.

2. Know Your Customer (KYC) Procedures

We employ a layered Know Your Customer (KYC) approach to verify the identity and legitimacy of our users. The level of verification required may vary depending on user activity and potential risk factors.

Level 1 (Basic Verification):

• Required for all users.
• Collects basic information such as full name, date of birth, residential address, country, and email address.

Level 2 (Enhanced Verification):

• Required for users exceeding specific deposit or withdrawal thresholds.
• Requires verification of identity through government-issued photo ID and proof of address documentation.

Level 3 (Optional Advanced Verification):

• For users engaging in high-risk activity or upon suspicion of potential money laundering.
• May involve additional verification measures such as source of funds documentation, bank statements, and tax returns.

3. Transaction Monitoring

We apply a robust and risk-based transaction monitoring framework to identify, evaluate, and respond to suspicious activities in real time and retrospectively. The purpose of this monitoring is to detect potential money laundering, fraud, or other financial crimes and to ensure that all user activity remains consistent with expected behavior based on the user's profile and source of funds.

3.1 Continuous Monitoring Protocol

All user activity on the platform is subject to ongoing surveillance through both real-time monitoring mechanisms and retrospective audits. Real-time monitoring is implemented to intercept and analyze user behavior as it occurs, focusing on financial transactions, login patterns, account changes, and interaction with payment instruments. This live oversight is crucial for preventing illicit funds from circulating through the platform and for identifying suspicious conduct before it escalates into criminal activity.

In parallel, post-transactional analytics are conducted on a daily and weekly basis. These reviews serve as a secondary layer of control, allowing the Compliance team to detect patterns that may not be apparent in isolated transactions. Retrospective monitoring involves batch analyses, profiling shifts, behavioral anomalies, and comparative trend analysis across user segments. These techniques are grounded in risk-based methodologies recommended by the Financial Action Task Force (FATF) and are essential for ensuring sustained AML compliance.

Long story short, all user transactions on the platform are subject to continuous monitoring using a combination of automated systems and manual oversight. This includes:

• Real-time Monitoring: Applied for all deposits, withdrawals, transfers, and in-game transactions to detect red flag behavior as it occurs.
• Post-Transaction Analytics: Conducted daily and weekly to identify patterns, trends, or anomalies that may have been missed in real-time detection.

3.2 Criteria for Monitoring

Transactions are flagged for review based on several predefined risk parameters, including but not limited to:

• Transactions that exceed EUR 1,000 in a single instance or cumulatively within a 24-hour period.
• Frequent deposits or withdrawals inconsistent with declared income or known gaming behavior.
• Use of multiple payment methods or frequent changes to linked bank accounts or wallets.
• Transactions involving high-risk jurisdictions or users flagged in sanction/PEP screening.
• Transactions lacking economic rationale or tied to little or no gaming activity.

Find more criteria in the red flags section below (section 4).

3.3 Transaction Risk Scoring

Each transaction is assigned a dynamic risk score, updated based on:

• User's KYC level
• Geographic risk
• Payment method
• Gaming behavior vs. financial activity
• Frequency, volume, and velocity of transactions

If a transaction or series of transactions surpasses a threshold score, it is automatically queued for escalation.

3.4 Review and Escalation Procedure

When a transaction is flagged:

1. Level 1 Review - Automated Alerts: A compliance bot assigns the initial classification (e.g., low, moderate, high-risk).
2. Level 2 Review - Compliance Analyst Evaluation: A human reviewer assesses flagged transactions using enhanced data points, including previous activity history, KYC file, and source of funds (if applicable).
3. Level 3 Review - Escalation to MLRO: If suspicion persists or legal reporting thresholds are met, the case is escalated to the Money Laundering Reporting Officer (MLRO) for decision on whether to file a Suspicious Activity Report (SAR).

All reviews are documented, timestamped, and stored securely for at least 5 years post-termination of the user relationship.

Once a transaction is flagged through our monitoring system, a structured multi-tier review process is initiated. At the first level, an automated risk engine classifies the alert based on pre-configured rule sets and machine learning models, assigning a preliminary risk rating. This allows for prioritization based on severity and urgency. The automation stage is not determinative; it functions solely as a triage mechanism to ensure resource allocation is optimized.

Transactions escalated for manual review are then examined by a compliance analyst. This Level 2 review involves verifying whether the transaction in question aligns with user-submitted documentation, declared source of funds, and behavioral history. Analysts consult the internal KYC file, transaction ledger, IP and device data, and any existing compliance notes before reaching a determination. Where there is unresolved suspicion or where the pattern suggests wider abuse, the case is escalated to Level 3.

At Level 3, the matter is referred to the MLRO for final assessment. The MLRO is legally responsible under AML regulations to determine whether the activity meets the threshold for filing a Suspicious Activity Report (SAR) with the Financial Intelligence Unit. All escalations are logged, timestamped, and stored in accordance with the EU's recordkeeping obligations under Article 40 of 5AMLD. Internal reporting chains and audit trails are designed to be regulator-accessible upon lawful request.

3.5 Timing of Checks

• Onboarding: Baseline transaction limits and monitoring parameters are assigned based on initial KYC tier.
• Daily: Transactions are reviewed in aggregate and per user to assess deviations from typical patterns.
• Event-Triggered: Enhanced monitoring is initiated immediately upon:
  • KYC level upgrades (e.g., reaching Level 2 or 3).
  • A failed transaction attempt.
  • An adverse media alert or PEP/sanction list hit.
  • Internal or external whistleblower reports.

3.6 Tools and Technology

Our AML program is supported by an integrated suite of compliance technologies designed to detect and mitigate financial crime risk efficiently and lawfully. The Company uses a central transaction monitoring platform that interfaces with its user database, KYC provider systems, and payment processors in real time. This integration allows for holistic user profiling and cross-referencing of financial activity with identity, location, and account metadata.

All transactions are screened against updated sanction and politically exposed person (PEP) lists using globally recognized databases compliant with the EU's AML/CFT directives and OFAC standards. These checks are applied at onboarding, at regular intervals, and on a per-transaction basis for high-risk accounts. The system also performs behavioral pattern recognition using machine learning algorithms, which are trained to adapt to evolving typologies of money laundering, fraud, and collusion.

Manual overrides-such as risk rating downgrades or SAR deferrals-are strictly controlled and must be justified in writing by a senior compliance officer, then approved by the MLRO. All overrides are automatically logged, cryptographically time-stamped, and included in the next compliance audit. This layered technology stack ensures both regulatory alignment and operational efficiency.

Manual overrides by compliance staff are logged and require dual approval.

3.7 Ongoing Calibration

Transaction monitoring rules are reviewed and adjusted at least quarterly. The calibration considers:

• Changes in regulatory guidance.
• Emerging criminal typologies.
• Internal audit findings or data quality issues.
• Feedback from financial institutions or regulators.

4. Red Flag Indicators

The identification of red flags is a critical component of our AML framework. These indicators serve as early warning signs that a user may be attempting to engage in suspicious, high-risk, or illegal behavior. While not conclusive evidence of wrongdoing, the presence of one or more red flags warrants further scrutiny and often triggers enhanced due diligence, temporary transaction holds, or escalation to the Money Laundering Reporting Officer (MLRO).

Red flag indicators may emerge at various stages of the user lifecycle, including onboarding, deposit and withdrawal activity, gameplay behavior, or during periodic reviews. During onboarding, the Company pays close attention to inconsistencies in submitted documents, such as discrepancies between names and addresses across forms of ID, or the provision of altered or digitally manipulated documents. Any attempt to bypass KYC requirements-for example, by submitting documents that are expired, unverifiable, or in a language not officially recognized in the user's jurisdiction-will immediately be flagged and may result in account suspension pending resolution.

During the transactional phase, red flags often manifest in the form of activity inconsistent with a user's known profile or declared source of income. A customer depositing significant funds shortly after opening an account, without any corresponding gaming activity, will raise concern. Similarly, frequent and structured transactions just below reporting thresholds (e.g., EUR 999 deposits over multiple days) may indicate an attempt to avoid detection and will result in a review of the user's complete transaction history. Rapid withdrawal of deposited funds, especially when no gaming or minimal play has occurred, may also be indicative of layering activity-a known stage in the money laundering process-and will prompt further investigation.

Geographic behavior is also closely monitored. If a user registers an account with a residential address in one country but consistently transacts from IP addresses located in high-risk or sanctioned jurisdictions, this mismatch will trigger a red flag. Likewise, the use of VPNs or proxy servers to mask geographic origin may be a technique used to circumvent territorial restrictions and will be treated as potentially suspicious behavior. In such cases, the Compliance team may request a signed proof-of-residency declaration, utility bill, or a live verification call, depending on the circumstances.

Where a user demonstrates unexplained affluence-such as depositing large sums inconsistent with their stated employment or without prior high-volume behavior-the Company will request source of funds documentation. This typically involves bank statements showing salary payments, a recent tax declaration, or in some cases, a notarized affidavit if conventional evidence cannot be provided. Users who refuse to provide this documentation will be denied access to further services and may be reported to authorities where legally appropriate.

Additional behavioral indicators include the opening of multiple accounts under similar names, the use of third-party payment instruments (e.g., cards not matching the account holder's name), and evasive responses to routine compliance queries. Users found attempting to manipulate the onboarding process-such as altering names, using alias email addresses, or providing different personal details in repeat submissions-will be considered high-risk, and their activities may be blocked pending a formal internal investigation.

Our platform integrates monitoring for both single-instance red flags and cumulative behavioral trends. Any red flag event leads to an immediate temporary hold on account transactions while the matter is reviewed by the Compliance team. A structured checklist is used to document the type, frequency, and severity of the observed indicators. In cases where red flags persist or are supported by additional risk factors-such as adverse media, PEP status, or high-risk country links-the file is escalated to the MLRO, and a decision is made on the need to file a Suspicious Activity Report (SAR) in line with applicable regulations.

Ultimately, red flag detection is not about rigid rules, but about context, patterns, and professional judgment. Our approach is designed to be adaptive, leveraging both automation and human oversight, and is continuously updated to reflect evolving money laundering typologies, regulatory expectations, and industry best practices.

Our most common Red Flags include, but are not limited to the following Red Flag Indicators:

• Inconsistencies or manipulation in KYC documents during onboarding.
• Transactions that are unusually large, structured, or inconsistent with user profile.
• Deposits followed by immediate withdrawals without gaming activity.
• Use of VPNs, proxies, or mismatched geographic information.
• Unexplained affluence triggering source of funds requests.
• Multiple accounts or third-party payment methods linked to one user.
• Evasive, incomplete, or misleading responses to compliance queries.
• Cumulative behavior patterns that indicate elevated risk.
• All red flags are documented, assessed by Compliance, and escalated to the MLRO where necessary.

5. Reporting Procedures

The Company maintains a clear, structured, and legally compliant procedure for reporting suspicious activity to the appropriate authorities. Our reporting framework ensures that any behavior potentially linked to money laundering, terrorist financing, fraud, or other financial crimes is promptly identified, documented, escalated, and, where applicable, formally reported in accordance with local and international regulations.

When a transaction, user behavior, or pattern is deemed suspicious-whether through automated detection, staff observation, or customer reporting-it is immediately flagged within our internal case management system. Each suspicious activity alert is reviewed by a designated compliance analyst, who gathers all relevant contextual data including user history, KYC documentation, transaction records, communication logs, and any previous compliance interactions. This data is compiled into a preliminary internal report and passed to the MLRO (Money Laundering Reporting Officer) for further evaluation.

The MLRO acts as the central authority for all reporting decisions and conducts a detailed analysis to determine whether the activity warrants the filing of a Suspicious Activity Report (SAR) or equivalent under the laws of the relevant jurisdiction. If a SAR is deemed appropriate, the MLRO ensures that it contains all necessary supporting information, adheres to format and filing guidelines, and is submitted within the prescribed timeframe to the Financial Intelligence Unit (FIU) or other competent authority.

To maintain confidentiality and avoid tipping off the user, all reporting is conducted discreetly and securely. No indication of internal concerns or investigations is communicated to the user involved or to any third party not legally entitled to the information. Internally, access to SARs and related documentation is strictly limited to compliance personnel and senior management with a clear "need to know."

Beyond formal SAR filings, the MLRO also maintains a log of all internal suspicious activity reviews, including cases where a decision is made not to report externally. These logs are retained for a minimum of five years and are made available to regulatory authorities upon lawful request.

Where appropriate, we also share intelligence or cooperate with law enforcement, regulators, or financial institutions, particularly in cases involving cross-border activity or links to known criminal networks. Such cooperation is always conducted in accordance with applicable data protection and confidentiality laws.

6. Training and Awareness

A strong culture of compliance begins with well-informed personnel. The Company has implemented a comprehensive AML training program that ensures all relevant employees possess the knowledge and tools necessary to detect, prevent, and respond to financial crime risks effectively. Training is mandatory for all staff with exposure to user accounts, financial operations, customer support, onboarding, or compliance functions.

At the time of hire, all new employees undergo initial AML training as part of their onboarding process. This introductory session covers the fundamentals of money laundering and terrorist financing, the Company's internal AML policies and procedures, KYC requirements, red flag indicators, and reporting obligations. Particular emphasis is placed on practical scenarios, common typologies, and case studies to promote real-world understanding.

Following onboarding, AML refresher training is delivered on at least an annual basis. This ensures employees remain up to date with regulatory changes, emerging risks, and updates to internal systems or protocols. Additional targeted training is provided whenever significant policy changes are introduced, or when new products, jurisdictions, or risk factors are integrated into the platform.

Staff in high-risk or decision-making roles, such as customer due diligence specialists or the MLRO, receive enhanced and role-specific training. This includes advanced modules on topics such as source of wealth verification, handling of politically exposed persons (PEPs), sanctions compliance, and the legal framework surrounding suspicious transaction reporting.

Training is delivered via a mix of e-learning modules, in-person sessions, compliance bulletins, and scenario-based workshops. Completion is tracked through a learning management system, and non-compliance with training requirements may result in disciplinary measures.

Beyond staff education, the Company is committed to promoting broader awareness of AML issues across its platform. Users are regularly reminded of the importance of honest disclosure, responsible gaming behavior, and the illegality of using the service for laundering purposes. Notices about KYC obligations, acceptable payment practices, and the consequences of suspicious activity are embedded within onboarding flows, FAQs, and Terms of Service.

This dual approach-internal training and external awareness-ensures a vigilant, well-prepared ecosystem that minimizes AML risk while supporting regulatory integrity and user trust.

7. Data Security and Confidentiality

The Company takes data protection seriously and implements strict technical and organizational measures to ensure the confidentiality, integrity, and availability of all personal and financial information collected during AML and KYC processes. All user data is stored in secure, access-controlled environments, with encryption applied both at rest and in transit. Access to sensitive information is restricted to authorized personnel on a need-to-know basis and monitored through audit logs to prevent misuse or unauthorized access.

We maintain compliance with applicable data protection regulations, including the General Data Protection Regulation (GDPR) where relevant, and retain AML-related records-such as customer identification, transaction data, and internal reports-for a minimum of five years after the end of the business relationship or the completion of an occasional transaction, whichever is later. Information may only be disclosed to external parties where legally required, such as in response to regulatory audits, court orders, or formal requests from law enforcement.

8. Policy Review and Updates

This AML Policy is reviewed at least annually to ensure it remains aligned with current legal requirements, regulatory expectations, and industry best practices. The review process is led by the Compliance team in coordination with the MLRO and includes assessment of recent case outcomes, risk assessment updates, internal audit findings, and any relevant legislative developments.

Interim updates may be made at any time if material changes occur, such as expansion into new jurisdictions, product modifications, or shifts in the risk landscape. All changes are documented, approved by senior management, and communicated to affected personnel through internal training or policy briefings. The latest version of the policy is always made publicly available on our website for transparency and accountability.

9. Contact Us

If you have any questions or concerns about our AML Policy, please contact our Compliance Officer at the chat widget on the site.

This AML Policy is effective as of 14.01.2026.