KYC Policy

Last updated: 2024-08-26

1. General

1.1 The Company adheres to and complies with “Know your customer” principles, which aim to prevent money laundering, financing of terrorism or proliferation of weapons of mass destruction through client identification and due diligence.

1.2 We take a risk-based approach and perform strict due diligence checks and ongoing monitoring of all customers and transactions. We utilize three stages of due diligence checks, depending on the risk, transaction, and customer type as well as other risk factors where applicable:

  • 1.2.1 Default Customer Due Diligence (“CDD”) - standard due diligence checks, used when appropriate procedures do not suggest low or high risk.
  • 1.2.2 Simplified CDD – used in lower-risk situations;
  • 1.2.3 Enhanced CDD – used for high-risk situations and includes requiring additional documents and information, and enhanced monitoring.

1.3 To this end, the Company reserves the right to request documents and information and take appropriate measures if such documents and information are not provided, or the provided documents and information are incomplete, inconsistent, or otherwise cannot be verified, or in other cases provided for in the Agreement or required by applicable laws.

2. Provision of Information and Documents

2.1 The minimum identification information to be provided consists of the following:

  • 2.1.1 Full name;
  • 2.1.2 Permanent residential address;
  • 2.1.3 Date of birth;
  • 2.1.4 Place of birth;
  • 2.1.5 Nationality;
  • 2.1.6 Identity number (or the passport No. if there is no identity number).

2.2 The Company may refrain from requesting some of the information specified above (except for full name, date of birth, and permanent residential address) in lower risk situations.

2.3 To verify the information provided, the Company will request the following documents upon you reaching certain thresholds or at an earlier moment:

  • 2.3.1 Unexpired identity document issued by a government (passport or ID card) – to verify your identity;
  • 2.3.2 Bank statement, utility bill, rental agreement, a letter from government authorities, in each case no more than 6 months old – to verify your permanent address.

2.4 You may be required to verify your identity and the lawful possession of payment means by providing photos and/or videos of yourself together with identity documents or payment means through specialized software.

2.5 In addition to the above, you may be required to provide information on the nature of your employment or business, as well as your annual income.

2.6 In higher-risk situations, the Company may request more detailed information and additional documents, including but not limited to the following:

  • 2.6.1 Information like occupation, previous address;
  • 2.6.2 Information on the intended nature of the business relationship;
  • 2.6.3 Information on the source of funds or wealth;
  • 2.6.4 Information on the reasons for intended or performed transactions;
  • 2.6.5 Documents to verify information such as proof of earnings (payslip/remuneration/dividends/pension); bank statement/savings account certifying consistent incoming values from an identifiable source; dated proof of an award/payment made to you; and other documents.

2.7 Source of funds refers to the funds being used to fund the specific transaction at hand.

2.8 Source of wealth refers to the origin of your entire body of wealth (i.e., total assets).

2.9 You may be required to make the first payment through an account in your name with a bank subject to appropriate CDD standards.

2.10 In certain situations, the establishment or continuation of a business relationship will require the approval of our senior management.

2.11 The documents provided might not be approved for the following reasons:

  • 2.11.1 Address/name on documents does not match with account name/address;
  • 2.11.2 Illegible documents or copies;
  • 2.11.3 Not acceptable documents (for example, a user sends a copy of a document that is not an accepted document for ID verification or a copy of a mail envelope instead of an actual utility bill);
  • 2.11.4 Any other reasons the Company shall deem appropriate.

2.12 The documents must be provided within 30 calendar days from the day of the request unless the earlier deadline was specified in the Company’s request.

2.13 Before the appropriate information or documents are provided, your access to the Services may be limited or suspended.

3. Payment Details and Update of Information

3.1 The Company has the right to terminate the user’s account if it suspects that the user uses a credit/debit card or any other form of payment that was not issued in their name.

3.2 You shall promptly notify us of any changes to details previously provided by you, including but not limited to your permanent place of residence, funds' source, financial standing, and other similar details.

3.3 From time to time, you may be requested to provide us with certain documents to verify the credit card details used by you to deposit money into your account. Depending on the outcome of these verification checks, you may or may not be permitted to deposit further monies with the credit card previously used by you. Should any of the information that you provide be untrue, inaccurate, misleading or otherwise not appropriate, you will be in breach of contract. In this case, we reserve the right to terminate your account immediately and/or prevent you from using the Services, in addition to any other action that we may choose to take.

3.4 We do not accept third-party payments. You must make deposits only from a bank account, bank cards, e-wallets, or other payment methods that are registered in your name. If during the security checks, we determine that you have violated this condition, your winnings will be voided, and the original deposit will be returned to the owner of the payment account. We are not responsible for the lost funds deposited from third-party accounts.