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Aml Policies
Purpose and scope
This Anti-Money Laundering (AML) Policy governs all activities conducted by Rkgg and applies to every customer, employee, contractor, and affiliate engaging in any wagering service offered by Rkgg. It sets out the controls required to detect and prevent money laundering and the financing of terrorism in connection with casino, sportsbook, live casino, slot games, and related products.
Regulatory framework
Rkgg operates in compliance with applicable anti-money laundering and counter-terrorism financing (AML/CTF) laws and directives. The policy aligns with recognized global standards and national implementing legislation. The Money Laundering Reporting Officer (MLRO) is responsible for ensuring ongoing compliance and for reporting suspicious activity to the competent authorities in accordance with law.
Customer due diligence and risk-based approach
Rkgg applies a risk-based approach to customer due diligence (CDD) and enhanced due diligence (EDD). Depending on the risk profile of a customer, the nature of the transaction, and the customer type, Rkgg assigns a risk tier and applies SDD, CDD, or EDD as required.
- SDD (simplified due diligence) is used for extremely low‑risk scenarios where proportionate controls suffice.
- CDD (standard due diligence) applies to the majority of customers and transactions.
- EDD (enhanced due diligence) is activated for high‑risk customers, large or complex transactions, or circumstances indicating elevated risk.
- Sanctions, PEP (politically exposed person) status, and adverse media are considered in risk assessments and screening procedures.
KYC process and data collection
Rkgg identifies and verifies customers at onboarding and maintains ongoing verification for the duration of the business relationship. Verification outcomes determine access levels and transaction capabilities.
- Identification data: full legal name, date of birth, nationality, current residential address, and contact details.
- Documentation: government-issued photo identification (front and back where applicable) and, where required, a supplementary document such as a passport or national ID card.
- Proof of residence: a recent document (bank statement or utility bill) not older than three months showing the customer’s name and address.
- Selfie verification: a recent selfie of the customer holding the ID document to confirm identity alignment.
- Source of funds and anticipated activity: explanation of funds’ origin and expected pattern of transactions.
- Age and jurisdiction checks: customer must be at least 18 years old and not be located in prohibited or restricted jurisdictions as determined by applicable law.
KYC thresholds and triggering events
Full KYC measures are triggered by either aggregate deposits exceeding EUR 5,000 over the lifetime of the account or by withdrawal requests or sequences of activity that raise suspicion or indicate potential non-compliance. When triggered, the customer shall complete the full KYC process and may be subject to temporary limitations on deposits or withdrawals until verification is complete.
Ongoing monitoring and screening
Rkgg performs continuous monitoring of customer activity and transactions using risk scoring. Automated and manual reviews assess consistency between customer profile, source of funds, and transactional behavior. Ongoing screening includes sanctions, adverse media, and high‑risk indicators; findings are escalated to the MLRO for action.
Record keeping and data retention
Rkgg maintains records of customer identification, verification results, risk assessments, and transactional data for a minimum of five years from the end of the business relationship, or for a longer period as required by applicable law. Records include copies of documents, digital verification logs, and decisions made under the policy.
Suspicious activity reporting and cooperation with authorities
Any suspicious or fraudulent activity identified by Rkgg will be reported to the competent authorities in accordance with applicable law. The company will preserve customer privacy to the extent required by law and will provide information solely to the extent permitted by regulatory and legal obligations. All such reporting will be conducted through the established MLRO process and in conformity with privacy protections.
Cash handling and payment channels
Rkgg prohibits cash transactions in excess of EUR 12,500 between counterparties. All deposits, withdrawals, and transfers must be conducted through traceable and regulated payment channels, and must be consistent with the customer’s verified profile and stated funding sources. Any attempt to deposit or withdraw via cash or cash-equivalent methods will be treated as a potential AML risk and may be declined or escalated for review.
Account restrictions and suspensions
If identity verification cannot be completed, if risk indicators are present, or if regulatory requirements are not met, Rkgg may restrict or suspend deposits, withdrawals, or access to certain features. Such actions remain in effect until compliance has been achieved or the investigation concludes.
Privacy and data security
Rkgg processes all personal data in accordance with applicable data protection laws. Data is stored securely, access is restricted to authorized personnel, and data retention adheres to statutory requirements and internal policies. Customers have rights to access, rectify, or erase personal data as permitted by law, subject to regulatory obligations and the needs of AML controls.
Training and governance
Rkgg maintains a formal AML governance framework with an appointed MLRO. All staff receive AML and KYC training on an annual basis, with additional training for roles with elevated risk exposure. Independent audits and periodic reviews verify compliance with this Policy and applicable law.
Policy review and updates
This Policy is reviewed at least annually and updated as required by changes in law, regulation, or business risk. Urgent updates may be issued in response to regulator guidance or significant risk events.