Aml

Anti-Money Laundering and Know Your Customer Policy for A6win

A6win maintains an AML/KYC program to prevent money laundering and the financing of terrorism in connection with all services offered on its platforms. The program encompasses customer onboarding, ongoing due diligence, transaction monitoring, record keeping, reporting, and staff training. It applies to all customers, products, and jurisdictions in which A6win operates and is implemented in accordance with applicable licensing conditions.

Scope and Application

This policy governs all customer accounts and activity on A6win platforms, including casino, sportsbook, live dealer, and related financial flows. All employees, contractors, and agents must comply with the policy as a condition of engagement with A6win.

Regulatory Compliance and Governance

A6win shall comply with applicable anti-money laundering, counter-terrorist financing, and data protection laws and regulatory requirements. The policy supports licensing obligations, record keeping, and reporting responsibilities imposed on the operator by the competent authority. An AML Compliance Officer leads the program and reports independently to senior management. The governance framework adopts a three-line defense structure: business units perform first-line controls; the AML function provides second-line oversight; independent audit reviews third-line controls.

Roles and Responsibilities

The AML Compliance Officer is responsible for implementing and updating the AML/KYC program, ensuring ongoing risk assessment, approving risk-based thresholds, coordinating due diligence, and ensuring training and awareness. All staff must promptly report any suspicious activity or potential non-compliance to the AML team through the approved reporting channels.

Customer Identification Program and KYC Procedures

1. Step 1 – Identity Verification On onboarding, collect and verify the customer’s legal name, date of birth, nationality, residential address, and contact details. Obtain a government-issued identity document (e.g., passport or national ID) and perform real-time identity verification, including a live verification check or equivalent biometric verification. Maintain a digital record of identity data for the customer’s file. Verification must be completed before or concurrent with the activation of customer accounts and transactional capabilities subject to screening.
2. Step 2 – Source of Funds Verification For deposits or transfers exceeding a predefined threshold (for example, the local currency equivalent of EUR 2,000 or USD 2,000) or when a transaction pattern appears inconsistent with the customer’s profile, obtain documentation evidencing the source of funds. Acceptable documentation includes recent bank statements, salary slips, or other official documents showing the origin of funds. Conduct automated checks against independent data sources and perform a secondary manual review if discrepancies arise. Funds may be temporarily held pending verification until documentation is reviewed and approved.
3. Step 3 – Source of Wealth and Enhanced Due Diligence For high-risk customers, politically exposed persons, or transactions exceeding higher thresholds (for example, EUR 5,000/USD 5,000 in a single event or cumulative within a 30-day period, or transfers to another user exceeding EUR 3,000/USD 3,000), obtain and verify the customer’s source of wealth. Acceptable evidence includes business ownership records, tax returns, corporate documents, or other lawful evidence of the origin and legitimacy of funds. A6win may require third-party verification or additional documentation, and may temporarily restrict or suspend activity until verification is completed to the satisfaction of the AML function.

Ongoing Transaction Monitoring

A6win conducts ongoing monitoring of customer activity to identify unusual or suspicious patterns. Monitoring is performed in two lines of control: first line—transactions are evaluated in real time by platform controls and payment providers with AML safeguards; second line—the AML team reviews activity against customer profiles, risk ratings, and escalation rules. Any anomalies trigger enhanced due diligence, manual review, and, if warranted, escalation to the competent authority in accordance with legal obligations.

Risk-Based Classification and Geographical Controls

Customers are categorized by risk based on nationality, geography, product usage, and transaction patterns into Low, Medium, or High risk. Low-risk customers follow standard verification and monitoring. Medium-risk customers require heightened monitoring and applied thresholds. High-risk customers or high-risk jurisdictions may be subject to restricted products, enhanced due diligence, or prohibition of service, as permitted by applicable law. The risk classification is reviewed at least annually and whenever there is a material change in a customer’s risk profile.

Record Keeping and Data Protection

All identification, verification, transaction, and due diligence records are retained for a minimum of ten years from the end of the business relationship or the last transaction. A6win maintains appropriate technical and organizational measures to protect personal data, including access controls, encryption, and audit trails. The operator acts as data controller; data may be processed by trusted service providers in accordance with data protection laws and the operator’s privacy policy. Data subjects may exercise access, correction, and deletion rights as provided by law via approved channels.

Suspicious Activity Reporting and Cooperation with Authorities

Any identification, transaction, or behavior that reasonably indicates potential money laundering or financing of terrorism shall be reported to the relevant supervisory authority or financial intelligence unit as required by law. A6win shall maintain internal procedures for the timely reporting of suspicious activity and shall cooperate with authorities during investigations, including providing access to records and staff as required by law. The operator shall terminate business relations with customers where required by law or where the risk remains unresolved after due diligence.

Training, Compliance Monitoring, and Policy Review

All staff receive AML/KYC training upon onboarding and at least annually thereafter, with updated curricula reflecting evolving risks and regulatory expectations. The AML program, including risk assessment, monitoring rules, and escalation procedures, is reviewed at least once per year or following material regulatory changes, with changes approved by the AML Compliance Officer and senior management.

Contact and Reporting Channels

For questions related to AML/KYC, customers and staff may submit inquiries through the official secure channels within the account portal. The AML Compliance Office will acknowledge inquiries and provide written responses in a timely manner in accordance with internal procedures.