AML Policy

Scope and Purpose
This policy governs onboarding, payments, account reviews, and investigations linked to the platform. It defines responsibilities, verification standards, monitoring rules, and reporting routes. Procedures here operate alongside our Terms and Conditions and applicable laws.

Customer Due Diligence (CDD)
We verify identity before meaningful play, payments, or withdrawals. CDD is completed using reliable sources and may include electronic checks and document review. Accounts remain restricted until verification is complete.
• Full name and date of birth
• Residential address and proof of address
• Source of funds information when risk indicators arise
• Verification of payment instruments used on the account

Enhanced Due Diligence and Triggers
Enhanced due diligence is applied when risk is higher. Triggers include complex ownership, high velocity of transactions, geographical risk, or politically exposed status. Document-only verification is not sufficient where risk is heightened.
Monetary triggers include a single withdrawal request of £3,000 or more, total withdrawals of £9,000 within 90 days, or patterns designed to avoid limits. In these cases we may require proof of source of funds and source of wealth, plus refreshed identity and address checks.

Monitoring and Suspicious Activity
We monitor accounts for unusual deposit and withdrawal behaviour, inconsistent gameplay, linked accounts, and use of third-party payment methods. Transaction histories are retained and reviewed on a rolling basis.
• Fragmented deposits followed by rapid withdrawals
• Repeated failed verification or inconsistent information
• Use of multiple instruments not in the customer’s name
• Attempts to bypass geographic or device controls
If suspicion arises, activity may be paused while we make enquiries. Tipping off is prohibited. Where required, we submit suspicious activity reports to the relevant authority.

Transactions and Limits
We may apply rolling thresholds, cooling-off periods, and payout reviews to manage AML risk. Card withdrawals and bank transfers of £3,000 or more in one transaction require management approval. We do not accept cash or anonymous instruments. We may refuse a transaction where verification fails or risk is unacceptable.

Record Keeping
Identity, transactional, and due diligence records are kept for at least five years from the end of the relationship or from the date of the last transaction, whichever is later. Records are accurate, retrievable, and available to regulators upon lawful request.

Sanctions and Prohibited Use
We screen against applicable sanctions lists. Access is refused or withdrawn where a match is identified or where funds may relate to criminal conduct. We do not provide services where doing so would breach sanctions or other legal restrictions.

Staff Responsibilities and Training
All relevant staff receive onboarding and periodic AML training covering risk indicators, escalation, and reporting duties. A designated officer oversees the framework, maintains registers, and ensures timely reporting. Failure to follow procedures may result in disciplinary action.

Data Security
We limit access to customer data, apply encryption where appropriate, and maintain secure storage and backup procedures. System logs support audit trails for AML reviews. Security controls are reviewed regularly to align with risk and regulatory expectations.

Account Actions
We may delay, block, or refuse any transaction and suspend or close accounts where AML concerns arise. These actions can occur without prior notice if required by law or to protect an investigation. Funds may be frozen pending the outcome of checks.