Kyc Policy
Scope and purpose
Jetwin maintains Know Your Customer (KYC) and Anti-Money Laundering (AML) controls to verify the identity of customers, assess and manage risk, deter illicit financial activity, and ensure compliance with applicable licensing and regulatory requirements governing online gaming operators.
Regulatory framework and governance
Jetwin operates under the licensing and regulatory framework applicable to online gaming and financial services in the jurisdictions where it offers services. This policy sets out Jetwin's approach to customer due diligence, transaction monitoring, and reporting obligations. Responsibility for the policy lies with senior management, with day‑to‑day duties allocated to a designated Money Laundering Reporting Officer (MLRO) and the Compliance function.
Risk-based approach
Jetwin applies a risk‑based framework to CDD and monitoring. Customer risk is assessed at onboarding and reviewed periodically, with higher scrutiny applied to elevated risk profiles. The risk rating informs verification requirements, ongoing monitoring intensity, and reporting obligations. All processing of personal data under this policy adheres to applicable data protection laws, and records are maintained to support regulatory and investigative needs.
Customer due diligence and enhanced due diligence
On onboarding, Jetwin conducts standard due diligence to establish customer identity, verify eligibility to participate, and assess potential AML risk. Enhanced due diligence (EDD) is applied to high‑risk cases, including but not limited to politically exposed persons (PEPs), customers from high‑risk jurisdictions, complex ownership structures, or patterns of activity that are unusual or opaque. EDD may include additional identity checks, source‑of‑fund documentation, and more frequent monitoring.
Identity verification and data collection
Jetwin requires verifiable identity information before enabling certain account activity. Accepted identity evidence includes a government‑issued photo document (e.g., passport or national ID) and a proof of address (e.g., utility bill or bank statement not older than 90 days). For non‑individual or corporate customers, additional documents detailing ownership and control may be required. Where appropriate, Jetwin may request a combination of documents from two independent sources to complete verification.
Source of funds and source of wealth
Jetwin requires customers to declare and substantiate the source of funds used for deposits and gameplay. For deposits or activity identified as high risk, customers must provide contemporaneous documentation demonstrating the origin of funds and, where applicable, the customer’s wealth. Acceptable evidence includes recent bank statements, salary or pension evidence, tax documents, or credible third‑party confirmations. Verification or re‑verification may be conducted at regular intervals or when the risk profile changes.
Ongoing monitoring and risk scoring
Jetwin continuously monitors account activity against the customer risk profile. Monitoring focuses on deposit history, wagering patterns, and deviations from expected behavior. When indicators trigger heightened scrutiny, the case is escalated for review, and supporting documentation is sought. All monitoring actions and resulting decisions are documented and retained for audit purposes.
Suspicious activity reporting and escalation
Any employee with knowledge or reasonable grounds to suspect money laundering, terrorist financing, or other illicit activity must report to the MLRO promptly and in any event within 24 hours. The MLRO assesses the information and, if warranted, files a Suspicious Activity Report with the competent authorities. Disclosure to the subject of an investigation or to third parties outside the formal reporting channel is strictly prohibited, and attempts to disclose is itself an offense.
Sanctions, PEPs and adverse media screening
Jetwin screens customers, counterparties, and beneficial ownership against sanctions lists and publicly available adverse information. If a match is identified, or if the customer is a PEP, Jetwin applies enhanced due diligence and, where necessary, restricts or closes accounts in accordance with applicable law and licensing conditions.
Record keeping and data retention
Jetwin maintains a complete and auditable record of all AML/CDD activities, including identity verification documents, risk assessments, transaction records, internal communications, SARs, and MLRO decisions. Records are retained for a minimum of five years after the end of the customer relationship or the final transaction, whichever is later, and longer retention may be used where required by law or licensing conditions. Data retention is implemented in accordance with applicable data protection standards.
Roles and responsibilities
Vetting and staff training
Jetwin conducts pre‑employment vetting, including identity verification and reference checks. All staff receive training on CDD/AML obligations, escalation procedures, and the prohibition on tipping off. Training is provided at onboarding and refreshed at least annually, with additional updates when regulatory changes occur.
High risk jurisdictions
Jetwin applies enhanced due diligence to customers from or transacting with jurisdictions identified by international bodies as high risk. Where licensing or regulatory requirements permit, Jetwin may restrict or terminate relationships with customers from such jurisdictions, or apply additional verification and monitoring measures as mandated.
Data privacy and protection
Jetwin processes personal data in connection with KYC/AML activities in compliance with applicable data protection laws. A Data Protection Officer oversees data protection governance, and Jetwin maintains processing records and access controls. Data subjects have rights of access, correction, objection, and erasure as provided by law. Information may be shared with competent authorities in accordance with legal obligations and data protection safeguards, including cross‑border transfers where permitted by law.
Amendments and notices
Jetwin may amend this policy to reflect changes in law, licensing requirements, or internal risk controls. Material changes will be communicated in accordance with regulatory obligations. Continued use of Jetwin services after notification constitutes acceptance of the updated policy.
Contact and queries
For questions about this policy, to submit a data subject access request, or to raise AML concerns, contact Jetwin Compliance or the MLRO through official corporate channels.