Know Your Customer (KYC)

1. Registration

   In order to use our service, customers are required to register. For registration customers need to provide our business with the following details:

   1. Email address
   2. Username
   3. Password
   4. Password confirmation
   5. Full name
      1. First name
      2. Last name
   6. Date of birth
   7. Permanent residential address
      1. Street and street number
      2. City
      3. Postal code
      4. Country
   8. Identity reference number
   9. Mobile number (optional)

   To complete the first registration phase (before CDD/EDD), the customer needs to verify the provided email or mobile number. A table indicating the customer privileges based on the verification stage is provided below.

   Registration phase		Can login	Can play	Can deposit	Can withdraw
   1	Registration without email/mobile verification	NO	NO	NO	NO
   2	Registration with email/mobile verification but not CDD/EDD	YES	YES, but subject to limited number of bets (verification pending)	YES, but limited amount of deposits or total amount of deposits (verification pending)	NO
   3	Registration with full verification and verification	YES	YES	YES, however it is Subject of EDD procedures based on risk	YES, however it is Subject of EDD procedures based on risk

   1. Registration Procedure

      1. Customer visits our web-based service to register
      2. Customer’s country origin (via IP address) is checked to verify that it is within the countries of our operation
      3. Customer completes the registration form
      4. Customer details are validated with the following rules
         1. Email must be unique among other registered customers
         2. Username must be unique among other registered customers
         3. Identity number must be unique among other registered customers
         4. Mobile number must be unique among other registered customers
         5. Passwords must be strong. A minimum of 8-10 characters long phrase that should at least include: 1 uppercase letter, 1 lowercase letter, 1 number and 1 special symbol
         6. Passwords should not contain the username, email, mobile number, date of birth or identity number of the customer.
         7. Customer age is calculated based on the given date of birth. Customers should not be minors.
      5. If validation is successful, the customer is registered
      6. Service sends verification email to the customer’s email address
         1. Once verified customer can login to our application
      7. (Optional) Service sends verification SMS to the customer’s mobile number

   2. Working with minors

      • Registrations with birth dates that indicate that a customer is a minor, are not accepted by the service.
      • If minors register with false details and provide legitimate documents for identification, this will result in their account being closed.

2. Verification

   Since during registration, the customer is not physically present but rather performs it via the internet, we apply CDD and risk-based EDD. EDD is always required as the customers’ risk level for ML/FT activities is considered high, due to the nature of the service (over the internet non face-to-face transactions).

   1. Email Verification Process

      1. Customer registers with a unique email address
      2. A verification email is sent to the email address specified by the customer, including a verification link
      3. Customers click on the link to verify their email address
      4. Email address of the customer’s account is verified

   2. Mobile Verification Process

      1. Customer registers with a unique mobile phone
      2. A verification message (SMS) is send to the mobile number of the customer, including a 6-digit code (numbers)
      3. The customer inputs the code in the mobile verification page of our service
      4. Upon successful completion, the mobile of the customer is verified

      In most countries, including the country/ies in which this service operates, mobile numbers of a natural person are registered and are associated with the natural person. Verification of the mobile can be considered as a means of CDD, since it is verified by mobile providers.

   3. Customer Due Diligence (CDD)

      • CDD always takes place after the user registration and before the user withdraws any funds from their account.
      • CDD also can take place before the customer deposits any amount other than the default limited amount that is meant to be allowed so that customers can test how the service works and what functionality it provides.

      1. CDD Measures

         • Identity Verification
         • IP-check
         • Double customer Check

      2. Identification details

         Upon registrations customers are required to provide additional documents so that their identity can be established/verified. CDD is needed to identify potential money laundering activity. The customer’s profile needs to be updated constantly so any unusual and suspicious activity can be identified and addressed. The identification details that need to be verified so that the customer can be considered as verified are the following:

         • Official Full Name
         • Date of Birth
         • Identity Reference Number
         • Permanent Residential Address
         • Nationality

      3. Verification Documents

         Verification takes place by making reference to official documents, data or information obtained from a reliable and independent source. For the purposes of verification, a reliable and independent source is considered one of the following: a government authority, department or agency, a regulated utility company or a subject person carrying out relevant financial business in Malta or a member state of the EU. This is because such entities would already have verified the identity and characteristics of the person to be verified by our service.

         Thus for the verification of full name, date of birth, identification number and nationality, we consult one of the following documents:

         • Valid unexpired passport
         • Valid unexpired national identity card
         • Valid unexpired driving license
         • Valid unexpired residence card

         For the verification of the residential address, it is performed by making reference to any of the following documents. The documents must not be more than 6 months old, thus any provided document must specify the date it was issued. The customer’s full name and address must be present and be accurate in all of the listed documents.

         • a utility bill
           • water supply company
           • power supply company
           • heating supply company
           • communication services (landline, mobile phone bills will not be accepted, since the residential address is not considered permanent)
         • a statement from a recognised credit institution or bank
         • an official conduct certificate
         • correspondence from a central or local government authority, department or agency
         • a record of a visit to the address by a senior official of the subject person;
         • an identification document listed (passport; national identity card; driving license, residence card) where a clear indication of the residential address is provided
         • any other government-issued document not mentioned above

3. Enhanced Customer Due Diligence (EDD)

   Since our customers are not face-to-face and our services are provided over the internet, the ML/FT risk is by default considered to be high and EDD must be applied. However, the extent to which we apply the EDD is determined by the individual customer’s risk level and our risk management procedures. All customers are subjects of EDD. When we apply EDD, we essentially apply extra measures to our customers so that we can have more identification details and minimize the risks of ML/FT. Currently, EDD is performed:

   • Always for new payment details (deposit/withdraw) debit/credit cards, bank accounts
   • Periodically, based on customer risk level

   In order to properly address the needs arising from EDD, we apply one or more of the following measures:

   1. Establish the identity of the customer with additional documentation and information
      1. As provided in section Verification Documents (sections in this document)
      2. Documents for EDD must be additional to the documents of CDD
      3. Documents for EDD that are of the same type (e.g utility bill) with documents obtained for CDD purposes, must be issued from different entities/ service providers
   2. Use supplementary measures to verify the provided documentation
      1. Certification by legal professional, accountancy professional, a notary or a person undertaking relevant financial business
      2. Obtained documents must be a true copy of the original, seen and verified by the certifier, including a photo of the subject customer
      3. The certification must include the certifier’s signature, profession, contact details and the document’s review date
      4. Extra attention should be paid to certified documents originating from high-risk jurisdictions
   3. Confirm (certify) the documentation, using a person carrying out relevant business with the subject

   1. Politically Exposed Persons (PEPs)

      A PEP is defined as a natural person who is or has been entrusted with prominent public functions. Close family members or persons known to be close associates of such persons (PEPs) are also considered as PEPs in the eyes of the law. Close family members include:

      • spouse/partner (recognized by law)
      • Children and their spouses
      • The parents

      PEPs are considered a high risk in regards to ML/FT because of their position which makes them vulnerable to bribery via funds that originate from illegal activities. Based on that, we apply extra EDD measures in relation to PEPs. These are:

      • Ask for senior management approval (risk management officer)
      • Establish the source of wealth and funds of the PEP
      • Enhanced monitoring

      To identify PEPs we consult the available PEP lists available in the countries of our operation. In case that the details of a customer potentially show that the subject customer is a public figure or a relative of one, we contact the customer and we apply EDD as described above.