Kyc Policies

Policy Purpose and Scope

Spinanga maintains this Anti-Money Laundering and Countering the Financing of Terrorism (AML/CTF) policy to prevent, detect, and report money laundering and the financing of terrorism in accordance with applicable laws, regulations, and regulatory guidance. The policy applies to all Spinanga customers, employees, contractors, agents, and associated operations across all platforms and jurisdictions in which Spinanga conducts business.

Definitions

For purposes of this policy, the following terms have the meanings set forth below unless the context requires otherwise: Money laundering means the process of disguising the origin of proceeds from criminal activity. Terrorist financing means the provision or collection of funds intended to support terrorist activities. Know-Your-Customer (KYC) refers to the procedures used to verify the identity of customers. Enhanced Due Diligence (EDD) denotes heightened verification and monitoring for higher risk relationships. Sanctions, Politically Exposed Persons (PEPs), and MLRO refers to the designated officer responsible for AML/CTF compliance.

Know-Your-Customer and Customer Identification

Spinanga shall identify and verify the identity of all customers prior to establishing a customer relationship and continue to conduct ongoing verification during the relationship. The information collected includes full name, date of birth, residential address, national identifiers where available, contact information, and email address. Acceptable documents may include government-issued photo identification and proof of address. For legal entities, corporate documentation establishing legal existence and beneficial ownership shall be collected and verified.

Verification shall be completed using reliable, independent sources and, where appropriate, corroborated by third-party identity verification services. The customer file shall record the verification status and the date of completion. If verification cannot be completed, Spinanga may suspend activity and reserve the right to terminate the relationship in accordance with applicable law.

Risk-Based Customer Due Diligence and Enhanced Due Diligence

Spinanga applies a risk-based approach to customer due diligence. Customer risk is assessed at onboarding and reviewed on an ongoing basis. Risk levels inform the depth of verification, monitoring, and escalation. Typical risk categories include low, standard, medium, and high.

• Standard due diligence applies to ordinary retail customers with routine activity.
• Enhanced due diligence (EDD) applies to high-risk customers, including politically exposed persons (PEPs), customers from high-risk jurisdictions, or customers engaged in transactions with unusual complexity or abnormal size.
• EDD requires additional identity corroboration, source of funds verification, ongoing enhanced monitoring, and, where applicable, senior management approval.

Ongoing Monitoring and Transaction Surveillance

Spinanga monitors customer activity on an ongoing basis to identify transactions that are inconsistent with the customer's risk profile or expected activity. This includes:

• Regular review of deposit, withdrawal, and wagering patterns;
• Automated screening against sanctions, adverse-listed entities, and PEP status;
• Periodic refresh of KYC data and proportional escalation for higher-risk accounts;
• Escalation of suspicious patterns to the MLRO for further investigation and potential reporting.

Source of Funds and Source of Wealth

For high-risk customers or transactions that exceed defined thresholds, Spinanga shall obtain and verify the source of funds and, when appropriate, the source of wealth. Acceptable documentation includes, but is not limited to, bank statements, payslips, tax filings, corporate financial statements, or other verifiable records. Spinanga may request declarations of source of funds for large or unusual activity and shall retain related disclosures in the customer file.

Suspicious Activity Reporting

Any Spinanga employee who knows, suspects, or has reasonable grounds to suspect that a customer is engaged in money laundering, terrorist financing, or other illicit activity must promptly report to the designated Money Laundering Reporting Officer (MLRO). Suspicious Activity Reports (SARs) shall be prepared in accordance with applicable law and submitted to the competent authorities as required. Tipping off or disclosure of an ongoing SAR to the customer or any third party is strictly prohibited. The MLRO shall maintain confidentiality and ensure timely handling of SARs and related investigations, with escalations to senior management as appropriate.

Sanctions, PEPs and High-Risk Jurisdictions

Spinanga conducts ongoing sanctions screening and PEP screening of customers and counterparties. Customers identified as PEPs or residents of high-risk jurisdictions shall be subject to Enhanced Due Diligence and heightened ongoing monitoring. Transactions with sanctioned individuals or entities are prohibited, and business with high-risk customers requires documented justification and approval by the MLRO. Spinanga reserves the right to refuse, suspend, or terminate any relationship where risk remains elevated and cannot be mitigated.

Record Keeping and Data Retention

Spinanga shall maintain comprehensive records to enable reconstruction of individual customer transactions and to support the investigation of potential illicit activity. Records shall include customer identification data, risk assessments, due diligence documentation, transaction records, SARs, communications with authorities, and internal audit findings. Such records shall be retained in accordance with applicable laws and regulatory requirements for not less than seven years, or as otherwise mandated in relevant jurisdictions.

Roles, Responsibilities and Governance

Senior management is responsible for the overall implementation and ongoing effectiveness of this policy. The designated MLRO has responsibility for receiving disclosures, coordinating investigations, filing SARs, and reporting to regulators as required. The Compliance function oversees policy adequacy, training, and auditing of AML/CTF controls. All staff share responsibility for complying with KYC, CDD/EDD, and monitoring requirements.

Training and Awareness

Spinanga provides regular AML/CTF training to all employees, including modules on customer due diligence, transaction monitoring, identification of suspicious activity, and escalation procedures. Training records are maintained to demonstrate compliance and to support regulatory reviews.

Confidentiality and Tipping Off

All information collected under this policy is treated as confidential. Disclosure of information is limited to regulators, law enforcement, or as otherwise required by law. Tipping off and disclosure that an AML/CTF investigation has commenced are strictly prohibited and may result in criminal or regulatory penalties.

Audit, Review and Continuous Improvement

The AML/CTF program is reviewed at least annually by the Compliance function and is subject to independent assessment where appropriate. Findings, risk assessments, and management responses are reported to senior management, with ongoing enhancements implemented to address evolving regulatory expectations and emerging risk factors.