Kyc & Aml Policies

Scope and Purpose

Psgames is committed to preventing money laundering, terrorist financing and sanctions violations in all aspects of its online gaming services. This Policy defines the minimum requirements for customer due diligence, ongoing monitoring, reporting, and governance to comply with applicable AML/CFT laws and to protect the integrity of the platform.

Governance and Compliance Oversight

The Company designates a Chief Compliance Officer (CCO) who is accountable for implementing, maintaining, and updating this Policy. The CCO reports directly to the Board and has independent authority to escalate concerns, initiate investigations, and file required reports with competent authorities in accordance with law.

Know Your Customer (KYC) and Customer Due Diligence (CDD)

• : Psgames collects only information reasonably required to verify identity and assess risk, including full legal name, date of birth, country of citizenship, residential address, and contact details.
• identity verification: the user provides a government-issued document (e.g., passport or national ID) and Psgames uses a trusted verification provider to confirm identity and authenticity. Address verification may be performed using a document dated within the last three months (e.g., utility bill or bank statement).
• legal capacity and age: applicants must be at least the legal gambling age in the relevant jurisdiction and be natural persons. Accounts opened for underage individuals will be closed and affected transactions reversed as permitted by law.
• jurisdictional screening: at onboarding, Psgames conducts geolocation checks and blocks access from Prohibited Jurisdictions. The user must declare nonresidence in Prohibited Jurisdictions, and IP-based geo-blocking will enforce restrictions.
• sanctions and adverse-list screening: applicants are screened against applicable sanctions and watch lists. A positive match results in onboarding denial and prompt reporting as required by law; the decision is documented in the customer file.

Ongoing Monitoring and Transaction Surveillance

Psgames conducts ongoing, risk-based monitoring of customer activity to identify money laundering, financing of terrorism, or sanctions breaches. Monitoring combines automated systems and manual review to identify suspicious patterns in deposits, funding sources, withdrawals, and the arrangement of transactions.

• transaction monitoring: patterns such as unusual size, frequency, or velocity are reviewed against risk factors and red flags. High-risk activity may trigger additional verification or restrictions.
• geolocation and time zone controls: device location is compared with claimed location. Inconsistent or masked locations may prompt further verification or temporary restrictions.
• anonymity and privacy controls: the use of anonymity-enhancing technologies is prohibited on the platform. Suspected use may result in suspension or denial of activity.
• wallet and address screening: wallet addresses and transactions are screened against sanctions and risk indicators using third-party analytics; high-risk addresses may be blocked from withdrawals.
• withdrawal and funding controls: withdrawals may be suspended or restricted pending due diligence for high-risk accounts or where required by policy; a withdrawal threshold may trigger additional verification independent of initial onboarding checks.
• redress and rebuttal: customers may provide additional information to rebut flags or suspensions, which will be reviewed promptly.

Enhanced Due Diligence (EDD)

When a red flag is triggered, Psgames applies Enhanced Due Diligence. EDD may include requiring the customer to provide, without limitation, the following: full legal name, country of citizenship, permanent residential address, identification number, government-issued ID, and documented source of funds and wealth. Psgames may engage third-party verifiers to assess the information. EDD procedures may require additional time, up to ten to fifteen business days depending on complexity and jurisdiction.

Politically Exposed Persons (PEP) and High-Risk Counterparties

Psgames recognises heightened risk for customers identified as Politically Exposed Persons or associated with PEPs. A risk-based approach is applied, with enhanced information requirements and more frequent monitoring where warranted by position, public funds exposure, or geography. The platform reserves the right to impose additional verification requirements or restrictions consistent with risk assessment outcomes.

Blocking, Freezing and Termination of Accounts

Psgames may block, suspend, or terminate accounts for any reason consistent with this Policy and applicable law. Grounds include failure to provide requested identification, submission of false or misleading documents, concealment of true location or identity, presence in Prohibited or sanctioned jurisdictions, or any material breach of the Terms of Service or this Policy. Blocking may include withholding funds or denying withdrawals until compliance requirements are satisfied. The Company may also reverse or withhold deposits if required by law or regulatory obligation.

Record Keeping and Data Protection

Psgames retains all KYC and AML records for a minimum of five years after account closure or last activity, in secure systems with access limited to authorized personnel. Personal data processing complies with applicable privacy and data protection laws, with appropriate safeguards for data transfers within the group and to trusted service providers under contractual arrangements.

Reporting and Cooperation with Authorities

Suspected money laundering, financing of terrorism, or sanctions violations identified through the program will be reported to the designated financial intelligence unit or competent authority in accordance with applicable law. The Chief Compliance Officer is empowered to prepare and submit such reports without awaiting additional approvals where legally permitted.

Training and Awareness

All staff involved in AML/CFT duties receive ongoing training on identification of red flags, due diligence procedures, data handling, and reporting obligations. Training is conducted at least annually and updated to reflect regulatory changes or material risk developments.

Vendor Management and Third-Party Risk

Psgames performs due diligence on third-party vendors engaged in identity verification, screening, transaction monitoring, data handling, or related AML/CFT functions. Vendors are assessed for AML controls, data security, auditability, and contractual rights to audit and terminate for non-compliance. Third parties must comply with this Policy and applicable law.

Policy Review, Governance and Updates

This Policy is governed by the Board and is reviewed at least annually. Material changes require formal Board approval and notification to users as required by law. The Policy takes effect on the date stated in the update and remains in force until replaced or amended.

Definitions

For purposes of this Policy, the following terms have the meanings commonly adopted in AML/CFT regimes: anti-money laundering, countering the financing of terrorism, customer due diligence, enhanced due diligence, sanctioned lists, politically exposed persons, suspicious activity reports, and financial intelligence units. Where used, these terms shall be interpreted to align with applicable laws and guidance.