Know Your Customer (KYC) Policy

1.Purpose and Scope of the KYC Policy

The purpose of this Know Your Customer (KYC) Policy is to establish a robust and practical verification framework for 3-102-936064 SOCIEDAD DE RESPONSABILIDAD LIMITADA, which governs your access to and use of this website (“the Operator”). This framework is designed to:

• Ensure full compliance with requirements imposed by the Anjouan Offshore Finance Authority and all applicable international AML/CTF standards, including the FATF Recommendations.
• Accurately identify and verify all players before they are allowed to engage in any financial transactions on the Operator’s platform.
• Prevent fraudulent activity, identity theft, and unlawful gaming participation by verifying user information prior to processing withdrawals or when regulatory thresholds are met.
• Foster a secure, transparent, and fully compliant gaming environment, protecting both the Operator’s business and its user community.
• Establish a foundation of trust between the Operator and its users, ensuring all funds are handled responsibly and that all gaming activity occurs within a legal and ethical framework.

This Policy demonstrates the Operator’s ongoing commitment to integrity, regulatory compliance, and operational accountability in all aspects of business.

2. Scope Of Application

This Policy applies to all operational aspects of the Operator’s business and covers the following:

• All Players: Every individual registering for an account is subject to KYC verification procedures, either at onboarding or when specified transactional thresholds are met.
• Third-Party Relationships: Any third-party service providers or business partners involved in payment processing, technical integration, or support functions are subject to due diligence and KYC screening requirements.
• High-Risk and High-Value Transactions: Any transaction that exceeds designated monetary thresholds or is identified as high-risk (whether by behavior, source of funds, or jurisdiction) will trigger enhanced KYC obligations.

This Policy is binding on all departments and staff engaged in player onboarding, compliance, payments, and customer support activities.

3. Key Objectives

• Regulatory Compliance: Adhere to all relevant local and international AML/CTF laws, including FATF standards.
• Player Integrity: Ensure that only verified, eligible players can participate, and mitigate risks of underage gambling, fraud, and financial crime.
• Risk Management: Identify and minimize risks associated with high-risk jurisdictions, Politically Exposed Persons (“PEPs”), and suspicious or complex transactions.
• Transparency and Responsibility: Promote safe gaming practices and protect player funds.

4. Principles of KYC Implementation

• Customer Identification: Verify player identity when cumulative deposits reach $10,000 USD or upon any withdrawal request.
• Risk-Based Approach: Apply different levels of due diligence depending on each player’s risk profile.
• Document Retention: Maintain all KYC documentation and transaction records for a minimum of five years.
• Ongoing Monitoring: Continuously monitor player activity and transactions for signs of suspicious behavior.

5. Customer Identification and Verification

Information Collection. Upon registration and as required by regulatory thresholds, the Operator collects the following player information, which serves as the foundation for player identification and ongoing risk assessment:

• Full legal name
• Date of birth (for age verification)
• Nationality
• Residential address
• Contact details (email and phone number)
• Payment method details
• Verification of Documentation

Document Verification. To validate player-provided information, the Operator requires and verifies the following documents:

• Proof of Identity: Acceptable documents include a valid government-issued passport, national ID card, or driver’s license, displaying the player’s photograph, name, and date of birth.
• Proof of Address: A recent utility bill, bank statement, or government correspondence dated within the last three months.
• Payment Verification: Documents or screenshots confirming player ownership of payment methods used.

Enhanced Due Diligence (“EDD”). EDD is triggered in any of the following circumstances:

• Players with high-risk profiles (e.g., PEPs, high-risk jurisdictions).
• Transactions or groups of linked transactions totaling more than $10,000 USD.
• Unusual or complex transaction patterns.

EDD measures may include:

• Verifying the source of funds and source of wealth.
• Additional identity validation (e.g., video verification, independent database checks).
• Increased frequency of account monitoring and transaction reviews.

6. Risk-Based Approach

The Operator employs a structured, risk-based methodology to determine the level of due diligence required for each player. The following risk factors are continuously assessed:

Geographic Risk: Players residing in countries or territories identified by the Financial Action Task Force (FATF) as high-risk or under increased monitoring are automatically subject to enhanced scrutiny.

Transactional Risk: Players who display high-frequency, high-value, or inconsistent deposit/withdrawal patterns, such as rapid velocity, sudden increases, or use of multiple accounts, are flagged for review.

Player Status: Players identified as Politically Exposed Persons (PEPs), those with adverse media exposure, or connections to known risk indicators will be classified as high-risk.

Based on this assessment:

Standard Due Diligence applies to low-risk players, involving routine ID and address verification

Enhanced Due Diligence is required for high-risk players, requiring additional checks, verification of source of funds, and more frequent monitoring.

7. Ongoing Monitoring of Player Activity

The Operator maintains continuous and automated monitoring systems to identify and respond to suspicious or non-compliant activity.

Transaction Monitoring: Automated systems are used to detect unusual transaction patterns, including:

• Large or unusual deposits and withdrawals
• Rapid movement of funds between accounts
• Multiple smaller transactions potentially structured to avoid reporting thresholds
• Use of multiple accounts or payment methods by a single user

Behavioral Monitoring: Player activity is analyzed for:

• Trigger Events for Review
• Periodic reviews of player accounts should be triggered by events such as:
• Account inactivity followed by large or unusual transactions
• Changes to player profile details (address, payment method, etc.)
• Alerts or notifications from third-party monitoring or data sources

These controls enable the Operator to adapt quickly to emerging risks and maintain continuous regulatory compliance.

8. Politically Exposed Persons (PEPs)

Identification: A Politically Exposed Person (PEP) is any individual who currently holds, or has previously held, a prominent public position, as well as their immediate family members and close associates.

Enhanced Due Diligence for PEPs: When a player is identified as a PEP, the following additional measures are mandatory:

• Independent screening using third-party databases and adverse media checks.
• Senior management approval is required before establishing or maintaining the relationship.
• Ongoing enhanced review of account activity and any changes in behavior.

All PEP-related accounts are treated as high-risk and are subject to the highest level of due diligence and monitoring in accordance with AML/CTF standards.

9. Record Keeping and Confidentiality

The Operator is committed to secure, confidential, and compliant data management practices:

• Retention of Records: All KYC documentation, transaction records, and related communications are securely retained for at least five (5) years from the end of the player relationship or last transaction, whichever is later.
• Data Protection: All player data is encrypted, access-controlled, and managed in full compliance with the Data Protection Act, GDPR, and other applicable data privacy laws. Data is used strictly for compliance, verification, and regulatory purposes only.
• Accessibility: KYC records are made available to competent regulatory authorities upon lawful request, including auditors, licensing bodies, and financial intelligence units. Confidentiality is maintained except where disclosure is required by law.

These measures ensure compliance with best practices in data governance and regulatory oversight.

10. Reporting Obligations

The Operator fulfils all mandatory reporting obligations related to suspicious and threshold-based transactions as required by Anjouan regulations and international AML/CTF standards.

• Suspicious Activity Reporting (SAR): A SAR is filed within seven (7) days of identifying or reasonably suspecting that a player or transaction may involve money laundering, terrorist financing, fraud, or use of false identity documentation. Each SAR includes detailed information on the player, relevant transactions, supporting documents, and a clear rationale for suspicion.
• Threshold Reporting: Any transaction, or series of linked transactions, exceeding $10,000 USD must be reported, even if no direct suspicion arises. This includes deposits, withdrawals, or transfers between accounts or payment instruments. Reports are submitted to the designated authority in the prescribed format and timeframe.

These obligations are fundamental to the Operator’s AML/CTF program.

11. Compliance Oversight and Staff Training

The Operator has implemented robust internal controls and designated personnel to ensure the ongoing effectiveness of its KYC and AML procedures.

• Compliance Officer: A dedicated Compliance Officer is responsible for supervising all aspects of KYC and AML compliance, including:
  • Overseeing the implementation of KYC procedures throughout the business
  • Ensuring timely and accurate submission of Suspicious Activity Reports (SARs) and threshold transaction reports
  • Acting as the primary point of contact for regulatory bodies, auditors, and law enforcement agencies
  • Monitoring regulatory developments and updating internal policies accordingly
• Internal Audits: Regular audits of the KYC/AML framework are conducted to assess procedural effectiveness, identify deficiencies, and ensure prompt implementation of corrective actions.
• Staff Training: All relevant staff undergo ongoing training covering:
  • Detection of forged or suspicious documentation
  • Recognition of red flags for fraud, money laundering, and terrorist financing
  • Proper escalation procedures and regulatory reporting requirements under Anjouan’s gaming regulatory framework

12.Penalties for Non-Compliance

Failure by the Operator to fully implement and enforce the provisions of this KYC Policy may result in serious legal, regulatory, and reputational consequences, such as:

• Administrative sanctions and monetary fines imposed by licensing authorities
• Suspension or revocation of the gaming license or other operational approvals
• Criminal investigation and prosecution in cases of willful non-compliance or facilitation of unlawful activity
• Regulatory blacklisting, restricting the ability to operate in other jurisdictions

13. Continuous Improvement

The Operator is committed to a proactive and adaptive approach to regulatory compliance. The KYC Policy is reviewed and updated on a regular basis to reflect:

• Amendments to Anjouan’s regulatory framework
• Changes in FATF standards and international AML/CTF guidelines
• Advances in technology for identity verification, fraud detection, and compliance automation
• Findings from internal audits and regulatory inspections

Where appropriate, advanced tools such as biometric authentication, artificial intelligence, and blockchain-based verification will be integrated to strengthen compliance protocols and operational efficiency

14. Contact Information

For inquiries, escalation, or regulatory matters related to this KYC Policy, please contact:

• 3-102-936064 SOCIEDAD DE RESPONSABILIDAD LIMITADA, Provincia 01 San Jose, Canton 01 San Jose, Distrito Carmen, Barrio Escalante, Avenida Siete, Calle Veintinueve, Edificio Dos Mil Novecientos Diez, Centro Corporativo AG.
• Email: Vladislava7867@gmail.com
• Website: w11.io / w11bet.io