Aml Policies

Introduction

Rkgg maintains an anti-money laundering and counter-terrorist financing program (the Policy) that governs all activities conducted on the Rkgg platform. The Policy applies to customer onboarding, account management, financial transactions, data handling, reporting obligations, and cooperation with competent authorities, in accordance with applicable AML/CFT laws and regulations.

Governing Framework and Risk-Based Approach

The Company applies a risk-based approach consistent with FATF guidance. Risk assessment covers three primary dimensions: customer risk, geographic risk, and transaction risk. The Policy is reviewed at least annually and whenever regulatory or industry guidance changes, with controls adjusted to address newly identified risks.

Customer Due Diligence and Verification (KYC)

Standard due diligence is performed on all customers. Verification is triggered by activity level and risk factors as set out below.

  • Trigger threshold: when the aggregate value of a users transactions reaches or exceeds USD 1,000, standard verification must be completed before enabling withdrawal or certain high risk transactions.
  • Documents and data: a clear copy or photograph of a government-issued identification document; a recent document confirming residential address; evidence of the ownership of the payment method (where applicable); a current photograph of the user holding the identification document; and any additional information requested by Rkgg to satisfy due diligence requirements.
  • Payment instruments: the name on the payment instrument must match the account holder's name; third-party deposits are prohibited; the Company does not accept anonymous payment instruments. If a deposit is funded via an electronic wallet, the wallet's registered email must match the account's registered email address.

Enhanced Due Diligence

Enhanced due diligence is applied for higher risk scenarios, including Politically Exposed Persons (PEPs), persons or entities subject to sanctions, and users from high-risk or monitored jurisdictions. Additional information on the source of wealth and the source of funds may be required. Senior management approval is required for proceeding with higher-risk activities, and the Company may request direct verification or additional documentation as a condition of continued access to the services.

Ongoing Monitoring and Suspicious Activity Reporting

All user activity undergoes ongoing monitoring for suspicious activity. Examples include unusual deposit patterns, rapid changes in device usage, the use of multiple devices or IP addresses, and inconsistent geolocation data. Suspicious activity is escalated to the anti-fraud/AML team for risk assessment and, where required by law, reporting to the competent authorities.

Transactions and Cash Flows

All withdrawals are subject to verification and compliance checks. The Company prohibits the use of anonymous or unverified payment methods and requires withdrawals to be made to an instrument belonging to the registered user. A one-time wagering turnover rule applies: the deposited amount must be wagered at least once before a withdrawal request can be satisfied. Example: a user deposits USD 100 and wagers USD 100; if the user then earns USD 58 in profit, the maximum withdrawal is USD 158, subject to verification outcomes. Users may increase wagering activity to unlock additional withdrawal flexibility consistent with the policy and applicable limits.

Record Keeping and Data Protection

Documents and data collected under this Policy, including identification, verification data, and transaction records, are stored and processed in accordance with applicable data protection laws and regulations. Rkgg will retain such information no longer than necessary to achieve the purposes of AML/CFT controls and as required by law, and in any event in accordance with GDPR and relevant national legislation. Access is restricted to authorized personnel, and appropriate security measures are maintained to protect data integrity and confidentiality.

Reporting Obligations and Cooperation

Rkgg will report suspicious transactions and activities to the competent authorities in accordance with applicable laws and regulations. The Company cooperates with regulatory and law enforcement inquiries, providing information to the extent permitted by law and subject to obligations of professional secrecy and data protection rules.

Amendments and Communications

This Policy may be amended from time to time. The Company will provide notice of material changes to registered users via the contact details on file or an in-platform notice, and continued use after notice constitutes consent to the revised policy.

Definitions

Anti-Money Laundering (AML): controls designed to prevent the laundering of funds or proceeds of crime. Counter-Terrorist Financing (CFT): measures to prevent funding of terrorist activities. Know Your Customer (KYC): the customer due diligence process. Politically Exposed Person (PEP): an individual entrusted with prominent public functions. Sanctions: lists and prohibitions issued by competent authorities. Geographic risk: risk arising from the customer's residence or location of the underlying transaction.

Responsible Gambling and Self-Exclusion

Rkgg supports responsible gambling initiatives and offers self-exclusion options consistent with regulatory requirements. Responsible gambling measures are not a substitute for AML/CFT controls; customers who self-exclude cannot later circumvent verification or AML requirements.