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Anti-money Laundering Policy

Scope and Purpose

9n9n maintains this Anti‑Money Laundering (AML) Policy to prevent laundering of illicit funds and the financing of terrorism in connection with all gambling services offered on the platform. The Policy governs all customers, accounts, deposits, wagers, withdrawals and transfers, and applies to all channels through which 9n9n provides its services.

Definitions

  • Customer: any person or entity that opens or uses an account with 9n9n.
  • Verification: the process of confirming identity and related information for compliance with AML laws.
  • KYC: Know Your Customer procedures described in this Policy.
  • Source of funds: the origin of funds used to deposit, wager or withdraw within 9n9n.
  • Politically Exposed Person (PEP): a person who holds or has held a prominent public function, and their family or close associates.

Identity Verification and Age Verification

9n9n conducts identity and age verification to satisfy applicable laws and regulatory requirements. Verification may be performed directly by 9n9n or via licensed third parties and competent authorities. During verification, 9n9n may restrict or delay withdrawals or other transactions as necessary.

  • Minimum data set: full name; date of birth; citizenship; permanent address; an identification number.
  • Required documents: valid passport or national ID card; document confirming residential address (utility bill, bank statement, etc.).
  • Additional documents: secondary national identity card (driver’s license, military ID, etc.); photos showing the user with the ID; card front with readable digits (the first six and last four digits visible, owner’s name and expiry readable).
  • Source of funds documentation may be requested to establish the actual origin of funds used for gambling. Acceptable forms include payslips, bank statements showing identifiable income, trust deeds, or dated award letters.
  • Timeframes: documents must be provided within seven days of account opening or of a request by 9n9n. 9n9n will review documents within seven days of receipt. Non‑compliance may suspend use of the account or restrict certain actions, including withdrawals.

Trigger Points for Enhanced Verification

Enhanced verification is triggered when the customer’s aggregate lifetime deposits reach or exceed 2,000 EUR or a withdrawal is requested. In such cases the customer enters a full KYC process and may receive a Temporarily Approved status with accompanying restrictions as described below.

  • During Temporarily Approved status, total deposits may be limited to 500 EUR in aggregate and withdrawals are disallowed until verification is completed.
  • Once verification is complete, the account returns to normal operation subject to ongoing AML monitoring and compliance checks.

Source of Funds and Financial Integrity

9n9n may require documentation to verify the source of funds used for gambling activities. Documentation may include one or more of the following where appropriate: payslips or evidence of director remuneration; bank or savings account statements showing consistent deposits from identifiable sources; entitlement evidenced by a trust deed; and dated evidence of awards or payments to the customer.

Due Diligence and Record Keeping

9n9n maintains a due diligence framework and keeps records of verification results, supporting documents, and related communications for as long as required by law and regulatory guidance. All data handling complies with applicable privacy and data protection requirements.

Anonymous and Duplicate Accounts

Anonymous or nom de plume accounts are not permitted. If the identity of an account holder cannot be determined, 9n9n shall close the account, cancel any winnings, and return deposits to the source account or withhold deposits where return is impracticable or costly.

9n9n shall identify and associate accounts that may be controlled by the same individual. 9n9n may cancel additional accounts or associated winnings and return deposits to the rightful owner where appropriate.

Politically Exposed Persons (PEP) and Risk-Based Approach

9n9n applies a risk‑based approach to customers who are PEPs or are family or associates of PEPs. Enhanced due diligence may be required, and 9n9n reserves the right to decline or terminate services for high‑risk individuals or relationships in accordance with policy and law.

Ongoing Monitoring and Screening

All customer activity is subject to ongoing monitoring for patterns of fraud, money laundering, or other illicit activity. Transactions and behavior are screened against risk indicators, and anomalies are escalated to the Compliance team for review and action, including suspension or termination of services where warranted by law or policy.

Actions on Non‑Compliance and Reporting

If verification cannot be completed, or suspicious activity is detected, 9n9n may restrict, suspend, or terminate access to services. Where legally required, 9n9n shall report to the competent authorities and cooperate with investigations, including providing information about identity, transactions, and source of funds.

Data Retention and Privacy

AML records, including verification documents and transaction data, shall be retained for the period required by applicable law. Access to these records is limited to authorized personnel and used solely for AML compliance, investigations, and regulatory reporting.

Governance, Training and Awareness

9n9n maintains an AML governance framework, with defined roles and responsibilities. Staff receive regular training on KYC procedures, suspicious activity indicators, data handling, and escalation processes.

Policy Review and Updates

This Policy is reviewed at least annually or whenever changes in law or regulatory guidance require updates. Implemented changes are communicated to relevant staff and, as appropriate, to customers through official channels.

Support, Contact and Appeals

For questions about AML or KYC, customers should contact 9n9n compliance through official customer support channels. All communications regarding verification decisions or AML actions are provided through secure and auditable channels.

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