Kyc & Aml Policies

Introduction

We88 is committed to preventing money laundering and the financing of terrorism in all of its operations. This KYC & AML Policy establishes the framework for customer due diligence, ongoing monitoring, reporting, and governance applicable to all We88 customers and services.

Scope and Application

This policy applies to all We88 customers and their activity on the We88 platform, including remote onboarding, deposits, withdrawals, and in-game or ancillary transactions. It covers all employees, contractors, and agents acting on behalf of We88.

Regulatory Framework and Compliance

We88 conducts its AML/CFT program in accordance with applicable laws, regulations, and licensing requirements. The program aligns with internationally recognized standards and supervisory expectations for online gaming operators. We88 reserves the right to update this policy to reflect changes in law, guidance, or regulatory expectations.

Definitions

• AML — measures aimed at preventing money laundering and related illicit activity.
• CFT — measures aimed at preventing the financing of terrorism.
• KYC — processes to verify customer identity and assess risk.
• CDD — customer due diligence performed on standard-risk customers.
• EDD — enhanced due diligence for higher-risk customers or transactions.
• PEP — politically exposed person or related parties.
• Source of Funds/Wealth — verification of the origin of funds used for transactions.
• Sanctions Screening — screening against applicable sanctions and adverse lists.

Governance and Roles

The Compliance Officer is responsible for implementing and maintaining the AML/CFT program. The Board provides oversight and ensures the allocation of appropriate resources. All staff must comply with this policy and participate in required training.

Customer Onboarding and Identity Verification

Onboarding includes verification of identity and assessment of risk. We88 requires:

• Name, date of birth, residential address, country of residence, contact details.
• Government-issued identification (passport, national ID, or equivalent) and proof of address (recent utility bill, bank statement).
• Age verification to confirm the applicant is 18 years or older; any participant under 18 is prohibited from gambling on We88.
• Evidence of Source of Funds for initial deposits, with documentary evidence where requested.
• Consent to identity verification through secure means, including non-face-to-face verification where permitted by policy and risk assessment.

Risk-Based Customer Due Diligence

We88 applies a risk-based approach to due diligence. Customers are categorized by risk level (Low, Medium, High) based on factors such as geography, product usage, expected activity, and onboarding channel.

• Low risk: standard identity verification and ongoing monitoring with periodic reviews.
• Medium risk: enhanced source of funds verification and increased monitoring frequency.
• High risk: comprehensive verification of beneficial ownership where applicable, enhanced ongoing monitoring, and senior management approval for the relationship.

Ongoing Monitoring and Transaction Surveillance

We88 employs ongoing monitoring of customer activity to identify anomalous behavior. Automated systems screen transactions for indicators of illicit activity, with manual review where warranted. Any suspicious activity must be escalated and reported in accordance with applicable law, typically within 24 hours of detection, to the appropriate authority and through the internal escalation process. The monitoring framework includes:

• Real-time or near real-time transaction screening against risk indicators;
• Periodic reviews of customer profiles and risk ratings;
• Investigation procedures for unusual or suspicious activity, with thorough documentation;
• Maintenance of complete audit trails for monitoring and investigations.

Enhanced Due Diligence for High-Risk Scenarios

In high-risk scenarios, We88 conducts enhanced due diligence, including:

• Comprehensive verification of Source of Funds/Wealth with documentary evidence;
• Verification of beneficial ownership where required;
• Expanded ongoing monitoring and periodic re-verification;
• Senior management approval for the establishment or continuation of the business relationship.

Sanctions Screening, PEP, and Adverse Media

All customers and related parties undergo sanctions screening. We88 also evaluates PEP status and considers adverse media as part of ongoing due diligence. Any positive match or elevated risk triggers escalation and potential reporting to the relevant authorities in accordance with law and policy.

Record Keeping and Data Retention

We88 retains all KYC records, transaction data, and related documentation for a minimum of five (5) years after account closure or the completion of the relevant transaction, or longer as required by applicable law. Retention includes identification documents, risk assessments, transaction logs, and communications related to due diligence and investigations.

Data Protection and Privacy

We88 processes personal data lawfully and fairly, collecting only information necessary for AML/CFT purposes. Security measures, access controls, and encryption protect data. Data subjects have rights to access, correction, and deletion to the extent permitted by law, and data may be shared with competent authorities as required by law.

Reporting of Suspicious Activity

We88 reports suspicious activity through established channels in accordance with applicable laws. We88 maintains confidentiality of reporting and will not disclose an investigation to the subject or other parties except as required by law or regulation.

Training and Awareness

All personnel receive AML/CFT training upon joining We88 and at least annually thereafter. Training covers regulatory obligations, red flags, escalation procedures, and the internal reporting process.

Third-Party Relationships and Outsourcing

We88 applies risk-based due diligence to agents, payment processors, and other service providers. Contracts require adherence to AML/CFT obligations, data protection, and reporting requirements. We88 reserves the right to terminate relationships presenting unacceptable risk.

Policy Review and Updates

This policy is reviewed at least annually by the Compliance Committee and approved by the Board. Updates are communicated to staff and implemented promptly.