Aml Policy

Introduction

10win maintains an anti-money laundering and counter-financing of terrorism (AML/CFT) program designed to prevent the use of the platform for illicit purposes, to detect and report suspicious transactions to the competent authorities, and to preserve information required for investigations. The program governs all customer onboarding, ongoing monitoring, data processing, and communications with authorities, and is overseen by the designated AML officer with authority to act promptly to ensure compliance.

Scope and Applicability

This policy applies to all users registering for or using 10win services, all employees, contractors, and service providers engaged in customer due diligence, payment processing, or transaction monitoring on behalf of 10win. It governs onboarding, ongoing monitoring, reporting, data retention, and cooperation with law enforcement and regulatory authorities as required by applicable AML/CFT laws and gaming regulations.

Governance, Roles and Responsibilities

10win designates an AML Officer responsible for maintaining the program, implementing updates, and coordinating with competent authorities as required. Senior management holds ultimate responsibility for the adequacy of the AML framework and ensures sufficient resources for its implementation. The AML Officer has authority to escalate issues, suspend or block accounts, and coordinate with relevant authorities, including providing information pursuant to lawful requests.

Know Your Customer (KYC) and Customer Onboarding

On registration or first use, the user shall provide mandatory information, including but not limited to full legal name, date of birth, residential address, valid electronic contact details, and primary payment instrument. The user warrants that all information supplied is true and correct. 10win reserves the right to suspend access pending verification and to close an account if information proves false or misleading.

• Identity verification documents: government-issued photo identification (e.g., passport, national ID, or driver’s license).
• Address verification: documents showing the user’s residential address (e.g., utility bill, bank statement) not older than the timeframe required by policy or law.
• Payment method verification: copies or images of the payment instrument used for deposits or withdrawals, with cardholder name matching the account holder and the first six and last four digits visible where required by policy.

Single Account and Access Controls

Users must not hold or operate more than one Member Account. If multiple accounts are detected, all related accounts may be blocked or closed, and any bets or winnings may be voided at 10win’s discretion. Access controls and authentication measures shall be maintained to prevent unauthorized account creation and to enforce identity verification requirements.

Risk Assessment and Customer Segmentation

10win applies a risk-based approach to customer due diligence. Risk indicators include geographic provenance, payment methods, device fingerprinting, IP address data, and observed transaction patterns. Customers identified as higher risk shall be subject to enhanced monitoring and proportionate additional verification in accordance with this policy.

Enhanced Due Diligence (EDD)

For high-risk customers or where required by law, 10win shall perform enhanced due diligence, including additional verification of source of funds, more frequent review of activity, and management-level authorization for continuing activity. Documentary evidence of source of funds and wealth may be demanded in accordance with applicable laws and regulations.

Ongoing Monitoring and Suspicious Activity Reporting

All customer activity is monitored for indicators of illicit activity. Indicators of suspicious activity include, but are not limited to: unusual deposit patterns, multi-device or multi-IP activity inconsistent with user profile, rapid and frequent transfers between payment instruments, geographical patterns inconsistent with declared residence, and resistance to verification. When suspicious activity is identified, it shall be escalated to the AML Officer for evaluation and, if warranted by law, reported to the competent authorities. Records of such actions shall be retained for audit and regulatory purposes.

Transaction Monitoring and Payment Integrity

All deposits and withdrawals shall comply with the following rules: the name on a payment instrument must match the registered account holder; for electronic wallets, the wallet email must match the registered email; 10win shall not accept or process payments from anonymous or opaque instruments and shall not credit or withdraw funds to third-party accounts not reliably attributable to the user. In the event of failed or unsettled payments, funds shall be held or redirected in a manner consistent with verification and legitimacy of ownership until resolution.

Record-Keeping, Data Retention and Protection

Documents and data obtained for verification, transaction data, and supporting evidence shall be stored securely in controlled systems and retained in accordance with applicable AML/CFT and data protection laws. Records shall be retained for a minimum period required by law, and in any event for at least five (5) years after account termination or long-term inactivity, unless a longer period is mandated by law. 10win shall implement appropriate technical and organizational measures to protect personal data, and ensure processing is lawful, fair, and transparent in accordance with applicable data protection standards.

Data Access, Rights and Privacy

Users have rights to access, correct, or request the deletion of personal data collected by 10win, subject to legal and regulatory constraints related to AML investigations and record-keeping obligations. Data processing shall be performed solely for purposes related to AML/CFT compliance, platform integrity, and regulatory obligations.

Third-Party Processors and Payments

10win may engage payment processors and service providers to facilitate deposits and withdrawals. All processors shall be engaged under written agreements that require adherence to AML/CFT controls. 10win remains responsible for compliance with this policy and shall exercise ongoing oversight of third-party activities affecting customer due diligence and transaction monitoring.

Cooperation with Authorities

10win shall cooperate with competent authorities in accordance with applicable laws. This cooperation includes providing information as permitted by law, preserving relevant records, and facilitating lawful investigations related to money laundering, financing of terrorism, or other financial crimes.

Staff Training and Awareness

All personnel undergo AML/CFT training at least annually or upon material changes to the policy. Training covers identification of suspicious activity, KYC requirements, record-keeping, data protection, and reporting procedures. Documentation of training is maintained for audit purposes.

Policy Amendments and Communication

10win reserves the right to amend this policy at any time. Material changes will be communicated to users by account notifications or email. Continued use of the platform after such notification constitutes acceptance of the revised policy.

Governing Law and Jurisdiction

This policy is governed by the laws applicable to 10win’s operations, and disputes shall be resolved in the competent courts within that jurisdiction, subject to regulatory requirements applicable to online gambling operators.

Effective Date

Effective date: 2025-01-01.