Anti-money Laundering Policy

Purpose and Scope

The Rkgg anti money laundering and know your customer policy establishes the standards to prevent money laundering and terrorist financing across all activities conducted on the Rkgg platform. This policy governs all customers, accounts, transactions, and business relationships and binds all employees, contractors, and representatives acting on behalf of Rkgg.

Regulatory Framework and Governance

Rkgg operates in compliance with applicable gaming and financial regulations. The Compliance Team oversees AML obligations, and a designated Money Laundering Reporting Officer (MLRO) has authority to escalate matters and coordinate with competent authorities. Training on AML, sanctions, and KYC controls is mandatory and conducted on a periodic basis.

Risk Based Approach

Rkgg applies a risk based framework to AML controls. Customer profiles, geographic risk, product type, and transactional channels determine the level of due diligence and ongoing monitoring. Higher risk scenarios trigger enhanced controls and require senior management review and approval before establishing or maintaining a business relationship.

Customer Due Diligence Levels

• Default Customer Due Diligence (CDD): standard identity verification and basic source of funds review before or during the onboarding process and on an ongoing basis as part of monitoring.
• Simplified CDD: applied only in clearly low risk circumstances with robust mitigating procedures and subject to ongoing monitoring.
• Enhanced CDD (EDD): applied in high risk scenarios including additional documentation, deeper verification of the source of funds and wealth, and intensified ongoing monitoring with management oversight.

Identification and Verification

Minimum identification information includes full name, date of birth, permanent residential address, nationality, and a government issued identity number or document. Verification materials may include a government issued photo ID, proof of address, and evidence of the source of funds. Identity verification is triggered when required by the risk assessment or when deposits or withdrawals reach defined thresholds.

Ongoing Monitoring and Transaction Surveillance

All transactions are recorded and reviewed for indicators of money laundering or terrorist financing. Transaction histories are cross referenced with account activity, communications, and other relevant data. High risk customers and politically exposed persons receive enhanced ongoing monitoring and periodic reviews.

Suspicious Activity Reporting

Any suspected money laundering or terrorist financing activity is investigated by the MLRO. If required by law, a report is submitted to the appropriate financial intelligence unit. Customer notification regarding investigations is restricted until the investigation concludes and disclosure is permissible under applicable law.

Prohibited Jurisdictions and Restricted Transactions

Rkgg prohibits account opening or funds transfers involving jurisdictions identified as high risk or subject to embargoes or sanctions. Where a customer is located in such jurisdictions or engages in restricted activity, accounts may be closed or transactions blocked in accordance with applicable law and internal procedures.

Documentation and Information Requests

Rkgg may request information and documents to verify identity, assess risk, and confirm the legitimacy of funds. Documentation may include government issued IDs, proof of address, proof of funds, and information about occupation, source of income, and purpose of transaction. Documents must be provided within a reasonable timeframe or access to services may be limited or suspended.

Source of Funds and Source of Wealth

Source of funds refers to the funds used for a specific transaction. Source of wealth refers to the overall origin of a customer’s assets. The company may require detailed information on both when conducting enhanced due diligence or when indicated by risk factors.

Payment Details and Account Ownership

Deposits must be made from payment methods registered to the customer in the customer name. The use of third party payments is not accepted. If third party funds are detected, winnings may be voided and the original deposit returned to the payor. Rkgg is not responsible for funds that originate from third party accounts.

Data Retention and Privacy

Personal data collected for AML and KYC purposes is retained in accordance with applicable data protection laws and regulatory requirements. Customer data is stored securely and retained for a minimum of eight years after the end of the relationship or last interaction, unless a longer period is required by applicable law. Data processing is conducted by Rkgg as data controller in accordance with the applicable data protection regime, and customers may exercise rights to access, rectify, or erase their data through defined channels.

Training and Internal Controls

Rkgg maintains an ongoing AML training program for relevant staff and implements internal controls to ensure proper identification, verification, monitoring, and reporting. The program includes record keeping, audit trails, and periodic review by internal and external auditors.

Policy Updates and Communication

This policy is reviewed at least annually or as required by changes in law. When updates are made, customers will receive notice and may discontinue use within a reasonable period not less than fourteen days before the changes take effect, if they choose to do so.

Contact Channel for AML/KYC Inquiries

Inquiries related to AML or KYC matters should be directed to the dedicated compliance channel within the platform. The Compliance Team will provide guidance and handle escalation as required.