Anti-money Laundering Policy

Introduction

333v is committed to preventing money laundering and the financing of terrorism in accordance with applicable laws and regulatory expectations. This Anti-Money Laundering (AML) and Counter-Tinancing of Terrorism (CTF) policy governs customer onboarding, ongoing due diligence, transaction monitoring, reporting, and governance across all activities undertaken on the 333v platform. It applies to all employees, contractors, and agents acting on behalf of 333v, and to all customers and counterparties engaging in services with 333v.

Scope and Definitions

For the purposes of this policy, the following terms shall have the meanings set out herein or as defined in the applicable Terms and Conditions: Money Laundering, Terrorist Financing, Customer, Transaction, Know Your Customer (KYC), Politically Exposed Person (PEP), Sanctions List, and Highest-Risk Jurisdiction. Where not defined herein, terms shall have their ordinary legal meanings as applied to gambling and financial services activities.

Governance and Compliance Oversight

333v appoints an AML Compliance Officer who bears responsibility for the ongoing design, implementation, and enforcement of the AML program, including policy updates, staff training, suspicious activity reporting, and interaction with competent authorities. The AML program adopts a risk-based approach, with escalation pathways for high-risk scenarios and authority to independently suspend or terminate activity where required by law or policy. The senior management has ultimate accountability for ensuring compliance and the integrity of 333v’s AML controls.

Customer Identification and Verification (KYC)

1. Identity verification: The customer shall provide full legal name, date of birth, country of residence, and contact details. 333v may verify identity using government-issued documents (passport, national ID, or driving license) or other approved sources. Verification occurs prior to establishing a business relationship and on an ongoing basis as risk factors change.
2. Proof of address: A current document evidencing residential address must be provided, such as a utility bill or bank statement, issued within the last three months. Clear readability and alignment with customer data are required.
3. Source of funds and wealth: For deposits meeting or exceeding defined thresholds, customers must disclose the source of funds and/or wealth. Acceptable evidence includes employment records, corporate ownership details with beneficiaries, inheritance, investment statements, or other verifiable documentation. 333v may request additional information to corroborate the source of funds.
4. Payment card information: Upon request, customers may be required to provide front and back images of payment cards used for transactions. The front image shall show the cardholder’s name, expiry date, and the first six and last four digits of the card number; the back image shall show the cardholder’s signature with the CVV/CVC masked. 333v shall handle such data in compliance with applicable payment card and data protection standards and shall minimize data collection.
5. Single customer policy: Each customer may maintain only one active account consistent with the customer’s true identity. In the event of suspected duplicate accounts, 333v shall investigate and may close duplicate accounts with associated consequences, including nullifying transactions and withholding bonuses.
6. Ongoing information accuracy: Customers must promptly update any changes to personal or contact information. Failure to provide or update information may result in account limitations, suspensions, or closure.

Ongoing Customer Due Diligence and Monitoring

333v conducts ongoing monitoring of customer activity to identify transactions that are inconsistent with the customer profile or materially unusual. The monitoring program assigns risk ratings and triggers enhanced due diligence for elevated-risk profiles, including certain cross-border activities, high spenders, or unusual transaction patterns. The monitoring program integrates automated analytics with human review to determine appropriate action, including escalation, temporary holds, or enhanced verification steps.

Politically Exposed Persons (PEPs) and Sanctions Screening

All customers are screened against applicable sanctions lists and PEP registries. Enhanced due diligence is applied to PEPs, their immediate family members, and known associates. Where a customer is identified as a PEP or presents heightened risk, 333v may require additional documentation and longer verification timelines, and may subject the customer to ongoing enhanced monitoring.

Geographic and High-Risk Jurisdiction Management

333v recognizes that certain jurisdictions present inherently higher AML/CTF risk. The policy establishes criteria for identifying high-risk jurisdictions and prescribes additional due diligence measures or restrictions. Where applicable and permitted by law, 333v may restrict or terminate relationships involving high-risk jurisdictions or counterparties sourced from those jurisdictions.

Transactions and Payment Controls

1. Cash handling: 333v does not accept cash deposits or issue cash withdrawals. All funds must be transmitted through approved electronic means or banking channels.
2. Transaction risk assessment: 333v reserves the right to refuse or suspend processing of any transaction if there are indicators of money laundering or terrorism financing, or non-compliance with internal controls.
3. Third-party payments: Deposits must originate from the account of the customer on file with 333v; third-party contributions are not accepted unless explicit pre-approved arrangements exist under regulatory guidance.
4. Account and name matching: The name on the account must match the name on the payment source. Withdrawals shall be to the same payee name and through the same method used for the deposit, unless otherwise permitted by applicable law.
5. Currency and records: Withdrawals should be conducted in the same currency as the deposit, subject to applicable currency controls. 333v maintains transaction records for a minimum of five (5) years after termination of the business relationship.

Account Management and Duplicate Accounts

333v prohibits the creation of multiple accounts by the same customer. If duplicate accounts are identified, 333v may close the additional accounts, render related transactions null and void, and recover any bonuses or promotional benefits. Funds deposited or withdrawn through duplicate accounts may be retained or recovered as permissible under applicable law and internal policy. Anonymous or unverified accounts are prohibited.

Third-Party Screening and Data Sources

333v employs reputable screening tools to verify customer identities and monitor against sanctions, PEP, and other risk indicators. Data obtained through screening is used solely for AML/CTF purposes and stored in accordance with data protection requirements and internal access controls.

Enterprise-Wide Risk Assessment and Ongoing Evaluation

333v conducts an enterprise-wide AML/CTF risk assessment to identify threats, vulnerabilities, and potential impacts across business lines. The assessment informs resource allocation, control design, and training needs. The assessment is reviewed regularly, with annual formally documented updates or sooner where regulatory or business changes demand.

Record Keeping and Data Retention

333v retains identification data, transaction records, and audit trails for a minimum of five (5) years following the end of the customer relationship, or longer where required by applicable law. Records are stored securely with access controls and encryption where appropriate, and are available for inspection by the appropriate regulatory authorities in line with legal obligations.

Suspicious Activity Reporting (SAR) and Cooperation with Authorities

Staff must report suspicious activity or transactions to the AML Compliance Officer. The AML team will assess suspected activity and determine whether a SAR should be filed with the relevant authorities, and whether customer relationship termination is appropriate. Reports shall be made in accordance with applicable legal and regulatory requirements; staff are not required to actively search for illicit activity but must report what is known or suspected from normal duties.

Training and Awareness

333v provides AML/CTF training to all staff, including onboarding and ongoing refreshers. Training covers identification of suspicious activities, risk-based decision making, and procedures for reporting and escalation. The AML Compliance Officer oversees the training program and maintains training records and effectiveness reviews.

Data Security and Privacy

333v implements appropriate information security measures to protect customer data, including role-based access controls, encryption for data at rest and in transit, secure storage of records, and regular security reviews. Data handling adheres to applicable privacy laws and internal data protection policies.

Policy Governance, Review and Amendments

This policy is reviewed at least annually and whenever regulatory changes, business activities, or risk indicators necessitate updates. Material amendments require approval by senior management, with customers notified of significant changes in a timely manner.