Aml

Purpose and Scope

This Anti‑Money Laundering (AML) Policy establishes the controls and procedures by which 93ok (the “Company”) prevents and detects money laundering and the financing of terrorism in relation to its online gambling services. The Policy applies to all customer accounts, products and channels offered by the Company, including casino, sportsbook and ancillary services, and to all staff and contractors engaged in delivering those services.

Regulatory Framework and Compliance Obligations

The Company operates under the laws of Curacao and complies with applicable international AML/CFT standards. Where relevant, this Policy is implemented in accordance with licensing conditions, local regulations and regulatory expectations, and with guidance issued by competent authorities. The Money Laundering Reporting Officer (MLRO) is the designated authority for compliance, investigation, and communication with authorities relating to AML/CFT matters. The Company will retain records and produce information to authorities in accordance with applicable law and regulatory requirements.

Risk‑Based Approach and Risk Classification

• 93ok employs a risk‑based framework to identify, assess and mitigate money laundering and terrorism financing risks associated with customers, products, services, and geographies.
• Risk classification comprises Low Risk and High Risk categories. All players commence at Low Risk unless information or behavior indicates higher risk, at which point Enhanced Due Diligence (EDD) is triggered.
• Risk factors include identity verification status, geographic location, source of funds, nature of activity, device and channel consistency, and historical transaction patterns.

Customer Due Diligence (KYC) and Identity Verification

To enable account onboarding and ongoing service, the Company conducts Know Your Customer (KYC) procedures as part of customer due diligence. The following information and verifications are required:

• Personal data: full name, date of birth, residential address, and current contact details (email and phone).
• Identity documentation: government‑issued photo ID (e.g., passport or national ID) and, where required, a secondary document to confirm identity and address (e.g., utility bill or bank statement dated within the last three months).
• Geographic eligibility: an IP address geolocation check at onboarding to ensure adherence to jurisdictional permissions; access from non‑permitted jurisdictions will be blocked.
• Account integrity: a single Player Account per natural person and verification of ownership of payment methods and accounts used for deposits and withdrawals.
• Ongoing verification: information may be re‑verified or enhanced at the Company’s discretion, including during withdrawals or when account activity appears unusual or high‑risk.

Enhanced Due Diligence (EDD)

EDD is applied when higher risk indicators are present, including but not limited to: residence in or transactions involving high‑risk jurisdictions, multiple accounts, potential collusion or syndicate activity, politically exposed person (PEP) status, or suspicious behavior. When EDD is triggered, the Company may request additional documentation (e.g., recent bank statements, source of wealth information, or proof of funds) and may require real‑time verification or enhanced monitoring for a defined period. The MLRO will determine the scope and duration of EDD and may place temporary restrictions on activity pending verification results.

Money Laundering Reporting Officer (MLRO) and Internal Controls

The MLRO oversees AML/CFT compliance, maintains oversight of KYC documentation, and coordinates suspicious activity investigations. The MLRO is the primary contact for regulatory authorities and will escalate anomalies to the appropriate jurisdictions as required by law. Internal controls include segregation of duties, access controls, and independent review of AML processes.

Monitoring of Customer Activity and Transactions

The Company employs continuous monitoring of customer accounts and transactions to identify unusual, suspicious, or potentially unlawful activity. Monitoring mechanisms include automated transaction screening, pattern recognition, and manual review by designated compliance personnel. Indicators of concern may include:

• Deposits without subsequent betting activity or abrupt changes in wagering patterns
• Structuring or rapid deposit/withdrawal sequences
• Disparities between declared source of funds and transaction history
• Frequent usage of multiple devices or IP addresses inconsistent with known customer information

When suspicious activity is detected, the Company will document the finding, conduct an investigation, and, where warranted, file a report with the appropriate authorities through the MLRO process. Records of all such investigations will be retained in accordance with legal requirements.

Unusual Activity and Multiple Accounts

93ok prohibits the creation of multiple accounts by a single person and monitors cross‑account indicators. If multiple accounts are suspected or confirmed, related accounts may be suspended or closed, and winnings or deposits may be withheld pending investigation. The Company will assess shared environment indicators (address, IP, device, payment methods) and may consolidate or suspend accounts as part of the investigation.

Withdrawals, Payments and Cryptocurrency Transactions

Withdrawal requests are subject to verification of identity and ongoing AML checks. Funds will be disbursed only to the verified player and to approved payment methods. The Company may suspend or withhold withdrawals pending satisfactory documentation or investigation of unusual activity. In relation to cryptocurrency transactions:

• Initial deposits must be conducted with cryptocurrency; subsequent deposits, wagers, and withdrawals must use the same cryptocurrency type.
• The Company does not convert cryptocurrency to fiat currency and does not operate as a financial institution earning interest on deposits.
• Identity, age, and address verification are required for all crypto transactions, and balances and solvency considerations may be reviewed to ensure funds originate from authenticated sources.

Data Protection, Privacy and Security

Personal data processed for AML purposes will be handled in accordance with the Company’s Privacy Policy and applicable data protection law. Information may be shared with third‑party verification providers and competent authorities where necessary to comply with AML/CFT obligations. Security measures include access restrictions, encryption, and recording of communications with customers for safety and compliance purposes.

Recordkeeping and Data Retention

The Company shall maintain records of identity verification, customer due diligence, transaction monitoring, suspicious activity reports, and investigations for a period not shorter than required by applicable law. Where permissible, records may be retained for longer periods to accommodate regulatory and supervisory needs.

Suspicious Activity Reporting and Cooperation with Authorities

Any transaction or activity that raises suspicion of money laundering or terrorist financing will be reported to the competent authority through the MLRO in accordance with applicable law. The MLRO maintains a record of all cases where reporting to authorities was deemed unnecessary and provides justification for such decisions where required by law.

Training and Awareness

All relevant personnel receive AML/CFT training at onboarding and on an ongoing basis. Training covers identification of red flags, escalation procedures, data protection, and cooperation with law enforcement and regulators.

Policy Updates and Governance

The Company reserves the right to amend this AML Policy at any time. Updates shall be communicated in accordance with regulatory requirements, and continued use of services after changes constitutes acceptance of the revised policy. Critical changes will be notified through the Company’s official channels.

Definitions and Key Roles

For the purposes of this Policy:

• “KYC” means Know Your Customer, including identity verification and due diligence activities.
• “CDD” means Customer Due Diligence, including standard verification measures.
• “EDD” means Enhanced Due Diligence, applied to higher‑risk counterparties or activities.
• “MLRO” means the Money Laundering Reporting Officer, the designated AML/CFT compliance lead.