KYC POLICIES

Know Your Customer (KYC) / Customer Due Diligence (CDD)

Our company is required to obtain information to identify customers and to verify the customer’s identification information. The reasons for carrying out KYC or customer due diligence are as follows:

1. to be confident that the customers are who they say they are
2. to determine whether customers are acting on behalf of others, and
3. to guard our company against being used for fraud, money laundering or other criminal activity

Identification

Identification takes place by obtaining personal details and other relevant information in relation to that person. Upon registration, the following information on each customer will be obtained:

1. Name and surname
2. Date of birth
3. Permanent residential address
4. Nationality

Other customer due diligence documents and status will be requested duri

Age verification

Our company is obliged by law to determine that the customer is old enough to be involved in gambling / lottery activities. Therefore, the customer’s date of birth must be obtained at all times. In fact, if the customer provides a date of birth which would not add up to the legal age of gambling / lottery in that jurisdiction, the registration will be blocked.

Our company will adopt any government tools available in each country for age or identification checking where we operate.

Identity and address verification

Verification of the identity of the customer occurs when the user has reached the 2000€ threshold or upon registration, if the customer is considered to be a high-risk customer, depending on the predetermined risk levels. In such cases, the customer will receive a notification to upload a verification document in the relevant section inside the customer Account. These documents will be reviewed and validated or rejected by employees of our company. In determining whether the customer reached the threshold of 2000€, we will not take into account the winnings accumulated from a previous transaction which had not been collected but is reused to purchase tickets. Therefore, spent winnings will not be included in the calculation for the 2000€ threshold.

The user will be subject to verification procedures if he carries out either a single transaction or smaller transactions which seem to be linked and reach or exceed the threshold of 2000€ either at the deposit or withdrawal stage. Transactions will be considered as linked when they are carried out by the same user during a single period of being logged on to the system.

Any of the following documents are accepted as a means of verification of identity as long as the document contains photographic evidence of the user and is valid and unexpired:

1. Passport
2. Driving license
3. National Identification card (photographic)

Any of the following documents are accepted as a means of verification of residential address as long as the document contains the current residential address of the customer and is not older than 3 months:

1. a recent statement or reference letter issued by a recognised credit institution
2. a bank statement
3. a recent utility bill
4. an official conduct certificate
5. any other government-issued document not mentioned

Documents used to verify the address of the customer must not be more than three months old. If documents are in a foreign language, our company will make sure that the relevant sections which provide evidence of the customer’s identity are translated and understood by our company.

If valid verification documents are not provided within 30 days from the moment they are requested, the business relationship will be terminated and a suspicious transaction report will be considered. Within the 30-day window, the customer shall be able to deposit and play but not withdraw.

Up to date documents, data or information

Once the KYC section of the website is fully implemented, it will serve as a document management system as well and therefore, automatically checks all verification documents to ensure that they are not expired.

Should a document expire, or further information be required, the customer will be notified and the accounts will be flagged. Withdrawals will not be processed until valid documentation is provided.

The frequency of reviews and ongoing monitoring must vary according to the risk scoring of the client. For higher-risk clients, ongoing monitoring is carried out every 6 months. This review will include a review of the customer’s habits and risk profile. For low-risk customers, this review is done every 18 months. Should an event trigger occur, raising a suspicion, the customer is to be re-assessed and reviewed irrespective of the intervals mentioned above.