Kyc Policy

Purpose and Scope

Rkgg recognises its obligation to prevent money laundering and the financing of terrorism and establishes this KYC Policy to govern customer due diligence, ongoing monitoring, and related compliance obligations across all player accounts within the Rkgg platform.

Regulatory Framework and Policy Objective

The policy is designed to comply with applicable anti-money laundering and counter-terrorist financing laws in the jurisdictions where Rkgg operates. Rkgg shall apply a risk‑based approach to customer due diligence and will update controls to reflect changes in law, regulatory guidance, and risk exposure.

Know Your Customer (KYC) and Identity Verification

  • 3.1 Minimum information required at onboarding: upon registration, Rkgg will collect and securely store the player’s date of birth (confirming they are over eighteen), full name, place of residence, payment information, a valid email address, and a user credential (username and password).
  • 3.2 Record-keeping and data protection: all identification information and documents will be retained securely in accordance with applicable data protection obligations and regulatory retention requirements.
  • 3.3 Prohibition on anonymous or fictitious accounts: Rkgg will not open accounts where the true beneficial owner is not identifiable to the satisfaction of the Company.
  • 3.4 Verification thresholds: before processing any payment in excess of EUR 1,000 per occasion or where payments to the account aggregate to EUR 1,000, documentary verification will be requested, including government-issued identity documentation and proof of address where permissible under data protection rules.
  • 3.5 Supplemental verification methods: in addition to documents, Rkgg may corroborate identity by comparing information with third-party references, public databases, financial references, or other reliable sources.
  • 3.6 Notice of verification: players will be informed that identification information may be sought to verify identity.
  • 3.7 Handling uncertainty: any employee who identifies uncertainty regarding the accuracy of player information shall promptly notify the AML Compliance Person, who will review and determine whether further identification is required and whether a report to the authorities is warranted.
  • 3.8 Non-compliance: if a player refuses or provides misleading information, Rkgg will not open a new account and may close any existing account after risk assessment, with the AML Compliance Person duly notified for potential reporting.
  • 3.9 Sanctions screening: if a player appears on applicable sanctions or restricted lists, the account will be immediately frozen and/or closed as required by law and policy.
  • 3.10 Material changes: if material personal information changes, updated verification documents will be requested and reviewed.

Continuous Transaction Monitoring and Due Diligence

  • 4.1 Objective: Rkgg will monitor account activity with emphasis on complex or large transactions and on patterns likely to relate to money laundering or terrorist financing.
  • 4.2 Monitoring framework: transactions are automatically monitored. Daily reports are generated for all transactions above EUR 1,000, including available identity documents and full account history; an additional per-user report is generated detailing ID documents and transaction history for those accounts with activity above EUR 1,000.
  • 4.3 Oversight: the AML Compliance Person is responsible for monitoring, reviewing detected activity, determining further steps, and documenting the process, including reporting to authorities where required.
  • 4.4 Risk indicators: indicators may include transfers to/from high-risk regions without a clear reason; many small deposits followed by rapid withdrawals; unexplained or patterned transfers with no plausible purpose.
  • 4.5 Suspicious activity handling: upon detection, the AML Compliance Person will determine the scope of investigation, which may involve internal data gathering, third-party data, contacting authorities, freezing the account, or filing a report.
  • 4.6 Accepted payment methods: Rkgg will not accept cash or other non-electronic payments. Accepted methods include credit cards, debit cards, electronic transfers, wire transfers, checks, and any method approved by the applicable regulators.
  • 4.7 Payout routing: winnings or refunds will, where feasible, be paid via the same route used to fund the account.
  • 4.8 Prohibition on inter-user transfers: transfers between player accounts are prohibited unless expressly permitted by policy and law.
  • 4.9 Third-party processors: when a processing service is used, it must provide transaction monitoring and screening compatible with these procedures; the AML Compliance Person will review the service agreement for adequacy.
  • 4.10 Record retention: transaction records will be retained in accordance with data protection and retention requirements applicable to the jurisdiction of operation.

Suspicious Transactions and Reporting

  • 5.1 Reporting obligations: the AML Compliance Person shall report suspicious deposits or transfers of EUR 1,000 or more (individually or in aggregate) where there is knowledge, suspicion, or reasonable grounds to suspect involvement in terrorism, sanctions violations, laundering, or other criminal activity, or where the transaction lacks an ordinary lawful purpose or plausible explanation.

Training and Governance

Rkgg will implement ongoing AML training for employees under the leadership of the AML Compliance Person and senior management. Training occurs at least annually and will be updated to reflect changes in the law, the Company’s size, and its player base.

Data Protection and Retention

All data processed under this Policy will be protected in accordance with applicable data protection laws. Data will be retained for the period required by law and regulatory guidance and will be securely stored with access restricted to authorized personnel.

Roles, Access and Contact

The AML Compliance Person is responsible for the governance and operation of the KYC program and escalation pathways. For policy inquiries or to initiate a verification review, contact the AML Compliance channel at [email protected].