KNOW YOUR CUSTOMER

(last updated 01.08.2025)

Customer Identification and Verification (KYC)

The formal identification of customers upon entering into commercial relations is a vital element, both for compliance with money laundering regulations and for the Know Your Customer (KYC) policy.

This identification relies on the following fundamental principles:

A copy of your passport, ID card or driving license must be provided, each shown alongside a handwritten note with six randomly generated numbers.

A second photo showing the face of the user/customer is also required. The user/customer may blur out all information on the ID except:

• Date of birth
• Nationality
• Gender
• First name
• Second name
• The picture

All four corners of the ID must be clearly visible in the same image, and all required details must be legible. We reserve the right to request unblurred versions of other ID data if necessary.

Additional checks may be performed by an employee based on the specific situation.

Proof of Address

Proof of address is verified using two independent electronic checks based on separate databases. If the electronic checks fail, the user/customer has the option to submit manual proof of address.

Accepted documents include a recent utility bill (issued within the last 3 months) or an official government-issued document confirming your place of residence.

To ensure fast approval, the submitted document should be high-resolution, show all four corners, and be clearly readable.

Examples of acceptable documents:

• Electricity bill
• Water bill
• Bank statement
• Any official government correspondence addressed to you

Additional checks may be conducted by an employee based on the situation.

Source of Funds

If a player deposits over €5,000, there is a process of understanding the source of wealth (SOW).

Examples of SOW include:

• Ownership of business
• Employment
• Inheritance
• Investment
• Family

It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible, an employee may request additional documentation or proof.

The account will be frozen if the user deposits this amount either in a single transaction or through multiple transactions that total €5,000. A manual email will be sent to the user, along with information displayed on the website.

The website may also request a bank wire or credit card transaction to further verify the identity of the user/customer and gain additional insight into their financial situation.

Basic Document for Step One

The basic document will be accessible via the settings page on the website. Every user must fill out the following information:

• First name
• Second name
• Nationality
• Gender
• Date of birth

The document will be generated and stored by an AI system. An employee may carry out additional verification if necessary based on the situation.

Risk Management and Levels of Due Diligence

In order to address different levels of risk and economic conditions around the world, the website will categorize countries into three regions of risk.

Region One: Low Risk

For all countries in Region One, the standard three-step verification process (as described earlier) will apply.

Region Two: Medium Risk

For all countries in Region Two, verification thresholds are lowered:

• Step One: completed as usual
• Step Two: triggered at €1,000 deposit, €1,000 withdrawal, or €500 tip
• Step Three: triggered at €2,500 deposit, €2,500 withdrawal, or €1,000 tip

Region Three: High Risk

High-risk regions will be banned from accessing the platform. The list of high-risk countries will be updated regularly in response to global developments.

Additional Measurements

In addition, an AI system overseen by the AML Compliance Officer monitors user behavior for any unusual activity and reports findings to a designated employee of the website.

Based on a risk-based view and general experience, human employees will recheck all verifications previously completed by AI or other employees, and may carry out additional checks as necessary depending on the situation.

A Data Scientist, supported by modern electronic analytics systems, also monitors for suspicious behavior patterns, such as:

• Depositing and withdrawing without longer betting sessions
• Attempts to use different bank accounts for deposit and withdrawal
• Nationality changes
• Currency changes
• Sudden changes in user behavior and activity
• Checks to confirm that the account is being used by its original owner

Additionally, users are required to use the same method for withdrawal as they used for deposit — at least for the amount of the initial deposit — in order to prevent money laundering.

Enterprise-Wide Risk Assessment (EWRA)

As part of its risk-based approach, the Website has conducted an AML “Enterprise-Wide Risk Assessment” (EWRA) to identify and understand risks specific to the platform and its business operations.

The AML risk policy is developed after identifying and documenting the inherent risks related to:

• Services offered on the platform
• Types of users the services are offered to
• Transactions performed by users
• Delivery channels used
• Geographic locations of operations, customers, and transactions
• Other qualitative and emerging risks

The identification of AML risk categories is based on the Website’s understanding of:

• Regulatory requirements
• Regulatory expectations
• Industry guidance

Additional safety measures are in place to mitigate the specific risks associated with online operations. The EWRA is reassessed annually.

Ongoing Transaction Monitoring

AML Compliance ensures that ongoing transaction monitoring is conducted to detect transactions that are unusual or suspicious when compared to the customer's profile.

Transaction Monitoring – Three Lines of Control

1) The First Line of Control

The Website works solely with trusted Payment Service Providers (PSPs), each of which has effective AML policies in place. This ensures that the majority of suspicious deposits are filtered at the PSP level, with proper execution of KYC procedures on potential customers.

2) The Second Line of Control

The Website ensures its network is aware that any contact with a customer, player, or their authorized representative must trigger due diligence procedures, particularly in the following cases:

• Requests for the execution of financial transactions on the account
• Requests regarding payment methods or services linked to the account

The three-step verification process, along with adjusted risk management measures, provides the necessary information about customers at all times.

All transactions are reviewed by employees under supervision of the AML Compliance Officer, who is in turn overseen by General Management.

Transactions submitted to customer support or compliance management must also undergo due diligence review.

The determination of the unusual nature of one or more transactions depends on a subjective assessment, based on the customer’s KYC profile, financial behavior, and the transaction’s counterparty.

These checks are conducted by automated systems, and then cross-checked manually by employees for added security. Transactions that appear unjustifiable or suspicious due to lack of clarity in origin or purpose are rapidly flagged as atypical.

Any Website staff member must inform the AML division if they observe atypical transactions that cannot be attributed to lawful activities or a known source of income.

3) The Third Line of Control

As the final line of AML defense, the Website conducts manual reviews of suspicious or high-risk users. This includes:

• Adverse Media Screening – Searching for negative news or public data on individuals/entities
• PEP Screening – Identifying persons in politically exposed positions or associated with them
• Sanctions Screening – Checking against international sanctions lists (e.g., OFAC)

If fraud or money laundering is identified, relevant authorities will be informed without delay.

Reporting of Suspicious Transactions on the Website

Internal procedures clearly define when and how staff members must report suspicious activities.

Reports of atypical transactions are analyzed by the AML team using a predefined methodology. Based on findings, the AML team:

• Decides whether a report should be sent to the FIU, in accordance with the Law of 18 September 2017
• Determines whether to terminate the business relationship with the customer

Procedures

The AML rules — including minimum KYC standards — are operationalized into internal procedures available via the Website's intranet.

Record Keeping

• Identification data must be retained for at least 10 years after the business relationship ends
• Transaction records must be retained for at least 10 years after the transaction or relationship ends
• All data is stored securely, both online and offline, and encrypted for protection

Training

Human employees will perform manual checks based on a risk-based approach, and receive specialized training to do so.

The training and awareness program includes:

• Mandatory AML training aligned with the latest regulations for all financial staff
• Academic AML onboarding sessions for all new employees

The training content is tailored to match the trainee’s role and department. Sessions are delivered by certified AML specialists from the AML team.

Auditing

Internal audits are conducted regularly, with formal reports prepared to evaluate and improve AML-related activities.