AML / KYC policy (draft)

Anti-money-laundering and know-your-customer controls help us prevent the service being used for money laundering, terrorist financing, fraud, sanctions evasion or other financial crime. They also help us confirm that an account and its funds belong to the person using them.

We apply a risk-based approach. A check can protect the service and other players, but a request for information does not by itself mean that we believe you have done something wrong.

The final policy will identify the applicable legal and regulatory duties in [Regulation reference]. Those duties may include gambling, anti-money-laundering, counter-terrorist-financing, sanctions and record-keeping requirements. This draft does not claim a specific regime until the owner confirms the reference.

• Baseline checks — account details, age and territory eligibility, and sanctions screening where required.
• Standard customer due diligence — identity and the relationship between the account, the player and the funding route when a legal threshold or risk signal calls for it.
• Enhanced due diligence — additional identity, source-of-funds or source-of-wealth information and a deeper review for higher-risk cases.

The final operating procedure will set the thresholds, evidence and decision owners for each tier. We may continue monitoring an account after a check is complete.

• When account information, age or location needs to be confirmed before access or a regulated transaction.
• When a deposit, withdrawal, transaction pattern or account activity reaches a legal or risk threshold.
• When information is missing, inconsistent, out of date, or changes in a way that requires a fresh check.
• At any other time needed to meet a legal, sanctions, fraud or responsible-risk obligation.

Important implementation note: in-app KYC document upload does not exist yet. The operator must provide an approved secure route before collecting identity documents. Contact [Support email] or use support for the current instruction, and never send a private key or recovery phrase.

We will keep customer-due-diligence, transaction and review records for [Retention period], or longer where a legal hold or another applicable duty requires it. Access is limited to people and providers who need the records for compliance, safety or support. The final policy will explain the confirmed period and any exceptions.

Where required, we may report suspected money laundering or other suspicious activity to the competent authority, refuse or delay a transaction, restrict an account, or close it. The law may prevent us from telling you that a report has been made or what checks prompted it. A report is not a finding of guilt.

For an AML or KYC question, email [Support email] or use support. Only provide documents through an approved route that we identify for your case.