Know Your Customer (KYC) Policy for Anjouan Internet Gaming Operators

The English version prevails.

1. Purpose of the KYC Policy

The Know Your Customer (KYC) Policy establishes mandatory procedures and standards to ensure that Internet Gaming Operators licensed in Anjouan:

• Verify the identity of their players.
• Prevent fraudulent activities.
• Comply with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations.
• Maintain a safe, transparent, and secure gaming environment.

2. Objectives of KYC

1. Compliance with Regulations: Ensure adherence to local and international AML/CTF laws and FATF recommendations.
2. Player Integrity: Verify the identity of players to prevent underage gambling, fraud, and financial crime.
3. Risk Mitigation: Minimize risks associated with high-risk jurisdictions, Politically Exposed Persons (PEPs), and suspicious transactions.
4. Transparency: Promote responsible gaming and safeguard player funds.

3. Scope

This policy applies to:

• All players registering for gaming services.
• Business relationships established with third-party service providers.
• Transactions exceeding designated thresholds or identified as high-risk.

4. Key KYC Principles

1. Customer Identification: Verify the identity of players when the total value of aggregate lifetime deposits reaches $10,000 USD or a withdrawal request of any amount.
2. Risk-Based Approach: Apply varying levels of due diligence based on the player’s risk profile.
3. Record Retention: Maintain all KYC-related documents and transaction records for at least five (5) years.
4. Continuous Monitoring: Monitor player behavior and transactions to identify suspicious activity.

5. Customer Identification and Verification Process

5.1 Information Collection

The following information must be collected from all players during registration:

• Full legal name.
• Date of birth (to confirm minimum legal age).
• Nationality.
• Residential address.
• Contact information (email and phone number).
• Payment information (e.g., bank account or e-wallet details).

5.2 Document Verification

Operators must obtain and verify the following documents:

1. Proof of Identity

• Valid government-issued ID, such as:

  • Passport.
  • National ID card.
  • Driver’s license.

• The ID must contain the player’s photo, name, and date of birth.

2. Proof of Address

• Recent utility bill, bank statement, or government correspondence (not older than three months).

3. Payment Verification

• Bank statements or screenshots showing ownership of payment methods used.

5.3 Enhanced Due Diligence (EDD)

EDD is required for:

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

EDD measures include:

• Verifying the source of funds and source of wealth.

• Conducting additional identity checks.

• Monitoring transactions more frequently.

• Screening customers against global sanctions and watchlists, including those issued by:

  • United Nations (UN)
  • European Union (EU)
  • Australian Government
  • U.S. Treasury Department (OFAC)
  • UK HM Treasury

6. Risk-Based Approach

Operators must classify players into risk categories based on:

• Geographic location: High-risk countries as per FATF guidelines.
• Player activity: Frequent or high-value transactions.
• Player type: PEPs or individuals with adverse media mentions.

Based on the risk classification:

• Low-risk players: Standard Due Diligence (SDD).
• High-risk players: Enhanced Due Diligence (EDD).

7. Ongoing Monitoring

7.1 Transaction Monitoring

Implement automated tools to monitor transactions for unusual activity, such as:

• Large deposits or withdrawals.

• Rapid movements between accounts.

• Multiple small transactions designed to evade reporting thresholds.

  7.2 Behavioral Monitoring

Identify patterns indicative of problem gambling, fraud, or potential ML/TF activities.

7.3 Trigger Events

Conduct periodic reviews of player accounts, triggered by:

• Account inactivity followed by large transactions.
• Player profile updates (e.g., changes in address or or payment method).
• Notifications from third-party monitoring services.

8. Politically Exposed Persons (PEPs)

8.1 Identification

PEPs include individuals who hold or have held prominent public functions, as well as their family members or close associates.

8.2 Enhanced Measures

• Conduct comprehensive checks using third-party databases.

• Obtain approval from senior management before establishing a business relationship.

• Regularly review the account and transactions for unusual activity.

8.3 Sanctions and Watchlist Screening

The Company, at a minimum, screens customers against a consolidated set of global sanctions and watchlists, including but not limited to:

• United Nations (UN) Sanctions List
• European Union (EU) Consolidated List
• Australian Sanctions List
• U.S. Treasury (OFAC) SDN List
• UK HM Treasury Financial Sanctions List

9. Record Keeping and Confidentiality

9.1 Retention Period

• Retain all KYC documents, transaction records, and communication logs for a minimum of five (5) years after the business relationship ends.

  9.2 Data Protection

• Securely store player data in compliance with the Data Protection Act and international privacy laws such as GDPR.

• Ensure player data is used solely for verification and compliance purposes.

  9.3 Accessibility

• Ensure that KYC records are accessible to regulatory authorities upon request.

10. Reporting Obligations

10.1 Suspicious Activity Reporting (SARs)

• Report suspicious activities within 7 days of detection.

• Include detailed information on the player, transaction, and reasons for suspicion.

  10.2 Threshold Reporting

• Report all transactions exceeding $10,000 USD, even if no suspicion arises.

11. Compliance Oversight

11.1 Appointment of a Compliance Officer

Every operator must appoint a Compliance Officer responsible for:

• Overseeing KYC implementation.

• Liaising with regulatory authorities.

• Ensuring the submission of SARs and transaction reports.

  11.2 Internal Audits

• Conduct periodic internal audits to evaluate the effectiveness of KYC measures.

  11.3 Training Programs

Train employees on KYC procedures, including:

• Identifying fraudulent documentation.
• Recognizing red flags for ML/TF activities.
• Reporting obligations under Anjouan’s regulatory framework.

12. Penalties for Non-Compliance

Failure to comply with KYC requirements may result in:

• Administrative penalties, including fines.
• Suspension or revocation of the operator’s gaming license.
• Referral for criminal investigation, if applicable.

13. Continuous Improvement

Operators are encouraged to:

• Regularly review and update KYC policies to align with changes in AML/CTF regulations.
• Adopt advanced technologies, such as AI and blockchain, to enhance verification processes and reduce fraud.

14. Contact Information

For assistance or inquiries regarding KYC compliance, contact:

• Email: [email protected]
• Website: Winlion.com

Disclaimer: This KYC policy is a framework designed to meet the regulatory requirements of the Autonomous Island of Anjouan. Operators must adapt this policy to their specific operational needs while ensuring full compliance with local laws and regulations.

Last updated: 2025-05-09