Kyc & Aml Policies

Scope and applicability

Iplgame maintains a comprehensive KYC and AML program designed to identify customers, verify identity and location, assess risk, and monitor activity. This policy governs onboarding, ongoing due diligence, data handling, sanctions screening, and cooperation with competent authorities for all Iplgame customers and products.

Regulatory framework and risk-based approach

Iplgame complies with applicable anti‑money laundering and countering the financing of terrorism obligations. The program applies a risk‑based approach, allocating due diligence levels based on product type, customer type, geography, and transaction profile. The policy requires ongoing monitoring of customer behavior and transactions and periodic reviews of risk classifications.

Definitions

• KYC: know your customer procedures to identify and verify the customer and assess risk.
• AML/CFT: anti‑money laundering and countering the financing of terrorism obligations.
• CDD: customer due diligence, standard verification for routine activity.
• SDD: simplified due diligence, applied to very low‑risk scenarios.
• EDD: enhanced due diligence, applied to high‑risk customers, large or unusual transactions, or special cases.
• PEP: politically exposed person, requiring heightened scrutiny.
• Beneficial owner: natural person who ultimately owns or controls a customer.
• Ongoing monitoring: continuous review of transactions and updated information during the relationship.

Triggers for KYC verification and enhanced review

Onboarding and ongoing activity may trigger full or enhanced verification. Specifically, the following thresholds or circumstances require completion of full KYC and ongoing due diligence:

• Aggregate lifetime deposits reach or exceed 5,000 EUR.
• Any withdrawal request is initiated on an account with potential risk indicators.
• Transaction patterns or information indicate suspicious activity or potential non‑compliance.

Verification steps and acceptable documentation

1. Identity verification
• Submit government‑issued photo identification (for example, an ID card, passport, or national ID) with full name visible; document must be valid and not expired within the next three months.
• Verification checks must confirm that the applicant’s name matches the account holder name, and the holder is aged 18 or older.
• Country of residence must not be a restricted jurisdiction as defined by Iplgame policies and applicable law.
2. Proof of residence
• Submit a document showing the customer’s current name and residential address (for example, a bank statement or utility bill) issued within the last three months.
• Document must reflect the same name as the identity document and correspond to the residence address on file.
3. Selfie with ID
• Provide a live selfie holding the same identity document presented for verification, ensuring legibility of the ID number and holder’s face for cross‑verification.

Ongoing monitoring and data handling

Iplgame conducts ongoing monitoring of all customer activity to identify suspicious or unusual patterns. Information collected for KYC purposes is processed solely for compliance with AML/CFT obligations and is stored in accordance with applicable retention requirements. Data collected may be shared with competent authorities or designated regulatory bodies where required by law or regulation.

Data retention and privacy

All KYC data and transaction records are retained for a period consistent with applicable law and regulatory guidance. Access to KYC information is restricted to authorized personnel and is protected by appropriate technical and organizational measures to prevent improper disclosure or loss.

Sanctions screening and restricted jurisdictions

Iplgame conducts ongoing sanctions and adverse-list screening. Accounts or transactions involving entities or individuals located in restricted jurisdictions, or linked to sanctioned persons, may be blocked or subject to enhanced scrutiny, and may be terminated in accordance with regulatory requirements.

Account restrictions and suspensions

Where KYC verification is incomplete, inconclusive, or ongoing due diligence reveals risk concerns, Iplgame may restrict transfers, deposits, or withdrawals or suspend the account pending completion of verification or resolution of risk factors. Customers will be notified of actions and provided a timeline for remediation where feasible.

Customer rights and dispute resolution

Customers have the right to access and correct personal data held by Iplgame, request information about the purposes of processing, and obtain explanations regarding decisions based on KYC/AML risk assessments. Disputes may be escalated to the compliance function for timely resolution.

Roles and responsibilities

Iplgame’s compliance function oversees the KYC/AML program, including risk assessment, due diligence determinations, documentation collection, and liaison with regulatory authorities. Staff responsible for onboarding and transaction monitoring receive ongoing training in AML practices, data protection, and regulatory updates.

Policy amendments

Iplgame reserves the right to amend this policy to reflect changes in law, regulatory guidance, or risk posture. Notice of material changes will be provided in accordance with internal governance procedures, and updates become effective upon publication unless otherwise stated.

Contact information

For questions or requests related to KYC and AML procedures, please contact Iplgame compliance at [email protected].