Anti-money Laundering Policy

Purpose and Scope

The Rkgg AML policy establishes the measures applied by the operator to prevent money laundering and the financing of terrorism. It governs all customers, accounts, transactions and activities conducted on or through the Rkgg platform and binds all staff, contractors and agents acting on behalf of Rkgg.

Regulatory Alignment and Risk‑Based Approach

Rkgg implements a risk‑based framework designed to identify, assess and mitigate money laundering and terrorism financing risk in line with applicable laws and regulations. Transactions and customer relationships are reviewed on an ongoing basis, with emphasis on proportional controls commensurate with risk levels. The policy recognises three levels of due diligence:

• Default Customer Due Diligence (CDD) — standard checks where risk indicators are not clearly low or high.
• Simplified CDD — reduced verification for clearly low‑risk situations, subject to ongoing monitoring.
• Enhanced CDD — intensified verification and monitoring for high‑risk scenarios, including elevated documentation requirements.

Rkgg may suspend or limit access to services where verification is incomplete or poses material risk, and will report suspicious activity to the relevant authorities in accordance with law.

Know Your Customer and Due Diligence

Rkgg applies KYC principles to identify customers, assess risk, verify identity and monitor transactions. Third‑party verification checks may be conducted as part of the due diligence process to validate identity and ensure funds used in the account are legitimate.

Minimum Information and Verification Thresholds

The minimum data required for customer identification includes:

• Full name
• Permanent residential address
• Date and place of birth
• Nationality
• Identification number or government‑issued document number

Additional information may be requested in higher‑risk situations, including occupation, source of funds and source of wealth, and details regarding the intended nature of the business relationship.

Documents and Verification Procedures

To verify identity and address, Rkgg may require:

• Unexpired government issued document (passport or national ID card)
• Proof of permanent address (bank statement, utility bill, tenancy agreement or government correspondence) dated within the last six months

Verification may involve submitting photographs or video alongside identity documents or payment instruments. The Company may request additional documents for higher‑risk cases, including employment details and sources of funds or wealth. Documents must be provided within 30 calendar days from the request, unless a shorter deadline is stated. Access to services may be limited or suspended while verification is pending. Documents may be rejected if there is a mismatch, illegibility, or non‑acceptable form.

Source of Funds and Source of Wealth

Rkgg distinguishes between source of funds (the funds used for a specific transaction) and source of wealth (the customer’s overall assets). Information on source of funds and wealth may be requested in higher‑risk situations and will be used to assess the legitimacy of the funds used in gaming activities.

Payments and Account Ownership

Deposits must originate from accounts in the name of the customer. In some cases, the first payment may need to be made from a bank account registered in the customer’s name and subject to appropriate CDD standards. Rkgg will terminate or suspend an account if it suspects that a payment instrument is not owned by the customer. If third‑party payments are detected, winnings may be voided and the original deposit returned to the owner of the payment instrument. Rkgg is not liable for funds deposited from third‑party accounts.

Ongoing Monitoring, Updates and Notifications

Rkgg maintains ongoing monitoring of customer activity and conducts periodic reviews of information on file. Customers must promptly notify Rkgg of material changes, including changes to residence, funds sources, financial standing and contact information. The Company may request updated documentation to verify any information already provided or to support new activities or higher‑risk transactions.

Senior Management Approval

In certain situations, the establishment or continuation of a business relationship requires prior approval from senior management. This may apply where risk indicators are elevated or where new product features are engaged.

Suspicious Activity Reporting

Rkgg will report suspicious activities or transactions to the appropriate regulatory bodies in accordance with applicable laws. Failure to provide requested information or to respond accurately may lead to account closure or other enforcement actions.

Record Keeping and Data Protection

Rkgg shall retain records of customer identities, supporting documents and transactional data for a minimum of eight years from the end of the business relationship or the date of the last transaction, in compliance with applicable data protection and AML rules. Personal data is processed only for purposes of AML compliance, fraud prevention and customer due diligence. Data subjects have rights of access, correction and deletion as provided by law. Rkgg acts as data controller for personal data collected in connection with AML compliance.

Data Privacy, Cookies and Security

Rkgg processes personal data in accordance with its privacy policy and applicable privacy and data protection laws. Cookies and similar technologies may be used to support security and compliance measures. Customers should review the privacy policy for details on data processing, retention, and security.

Age Restriction and Lawful Use

Rkgg provides services only to individuals aged eighteen or older. The policy and account relationships remain subject to applicable law and licensing conditions.

Policy Governance, Updates and Communication

This AML policy is reviewed periodically and updated in line with changes to laws and risk factors. Any material amendments become effective no sooner than a two‑week period after notice to customers. The latest version governs all activities from the effective date stated.