This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Kassabet Casino, operated by Innovex Tech Holdings Ltd. (registration no. 15736, Costa Rica) and licensed by the Anjouan Gaming Board, in relation to identity verification, the prevention of money laundering, terrorist financing, and related financial crime. The Policy applies to all persons who register an account at kassa-bet.com and governs the collection, verification, and monitoring of customer information throughout the account lifecycle.

1. Legal Framework and Regulatory Basis

Kassabet Casino operates under the licence granted by the Anjouan Gaming Board. As a licensed online gambling operator, Kassabet Casino is required to maintain robust systems and controls to prevent the use of its platform for money laundering, terrorist financing, fraud, or any other financial crime. This Policy is designed to meet those obligations and to reflect international AML/CFT standards, including the recommendations of the Financial Action Task Force (FATF).

Innovex Tech Holdings Ltd. is responsible for the implementation and ongoing oversight of this Policy. All employees, contractors, and third-party service providers involved in the operation of kassa-bet.com are required to act in accordance with its provisions.

2. Definitions

• AML — Anti-Money Laundering: the set of procedures, laws, and regulations designed to stop the practice of generating income through illegal actions.
• KYC — Know Your Customer: the process by which we verify the identity of our customers and assess relevant risk factors.
• CFT — Countering the Financing of Terrorism: measures taken to prevent funds from being used to finance terrorist activity.
• Customer — any individual who has registered or attempted to register an account at kassa-bet.com.
• CDD — Customer Due Diligence: standard identity and risk verification applied to all customers.
• EDD — Enhanced Due Diligence: additional verification measures applied to higher-risk customers or transactions.
• PEP — Politically Exposed Person: an individual who holds or has held a prominent public function, or who is a close associate or family member of such a person.
• SAR — Suspicious Activity Report: an internal or regulatory report filed when suspicious behaviour is detected.
• MLRO — Money Laundering Reporting Officer: the designated officer responsible for overseeing AML/KYC compliance at Kassabet Casino.

3. Risk-Based Approach

Kassabet Casino adopts a risk-based approach to AML and KYC compliance. This means we assess the level of risk associated with each customer and each transaction, and we apply proportionate measures accordingly. Factors taken into account when determining risk include, but are not limited to:

• The customer's country of residence and nationality;
• The source of the customer's funds and wealth;
• The volume, frequency, and pattern of transactions;
• Whether the customer is a PEP or is subject to international sanctions;
• The payment methods used;
• Any unusual or inconsistent patterns of play or withdrawal behaviour;
• Any derogatory information available from open-source checks or third-party screening.

Customers identified as presenting a higher risk will be subject to Enhanced Due Diligence. We reserve the right to apply EDD at any point in the customer relationship, regardless of whether a specific trigger event has occurred.

4. Customer Due Diligence (CDD)

4.1 When CDD Is Conducted

Standard Customer Due Diligence is initiated at registration and may be triggered at various points thereafter, including but not limited to:

• Upon registration of a new account at kassa-bet.com;
• Before processing any withdrawal request;
• When cumulative deposits or withdrawals reach internal thresholds;
• When transaction patterns or account activity raise concerns;
• When previously submitted documentation has expired or is no longer valid;
• At any time we consider it appropriate based on a reassessment of risk.

4.2 Information We Collect

As part of standard CDD, Kassabet Casino collects the following information from all customers:

• Full legal name;
• Date of birth;
• Residential address;
• Email address and contact telephone number;
• Payment method details used to deposit or withdraw funds;
• Nationality and country of residence.

4.3 Documents We May Request

To verify the information provided, we may request one or more of the following documents:

Proof of Identity (one of the following)

• Valid government-issued passport;
• National identity card (front and back);
• Valid driving licence (front and back).

Proof of Address (one of the following, dated within the last three months)

• Utility bill (gas, electricity, water, or landline telephone);
• Bank statement;
• Official government correspondence;
• Council tax or local authority notice.

Proof of Payment Method

• For card payments: a copy of the card used (showing only the first six and last four digits, with the CVV obscured);
• For e-wallets or digital payment services including Apple Pay and Revolut: a screenshot of the account showing the customer's name and account identifier;
• For cryptocurrency transactions: the wallet address used and, where required, evidence of ownership;
• For other methods: equivalent documentation as reasonably requested.

5. Identity Verification Technology

Kassabet Casino uses Sumsub, an industry-leading identity verification platform, to process and authenticate KYC documentation submitted by customers. Sumsub facilitates automated document checks, liveness detection, and database screening, enabling us to conduct verification efficiently and securely. All data submitted through the Sumsub platform is processed in accordance with applicable data protection law and our Privacy Policy, published at kassa-bet.com.

All connections to kassa-bet.com are protected by SSL (Secure Sockets Layer) encryption. No KYC document or personal data is transmitted or stored without appropriate technical safeguards in place.

6. Verification Timelines and Account Restrictions

Customers are encouraged to complete KYC verification promptly upon request. The following conditions apply while verification is pending or incomplete:

• Kassabet Casino may place temporary restrictions on withdrawals until KYC is fully completed to our satisfaction;
• Deposits and gameplay may continue during the verification process at our discretion, subject to applicable limits;
• Withdrawals are reviewed and processed within two business days after KYC has been successfully cleared;
• Where documentation is submitted but requires further review, we will endeavour to communicate the outcome to the customer as promptly as reasonably practicable;
• Failure to provide satisfactory documentation within a reasonable timeframe may result in the suspension or permanent closure of the account.

7. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to customers who present a higher level of risk. Circumstances that may trigger EDD include:

• The customer is identified as a PEP or a close associate or family member of a PEP;
• The customer is a national of, or resident in, a high-risk or non-cooperative jurisdiction as identified by FATF or other relevant bodies;
• The customer's transaction volumes or patterns are inconsistent with their stated profile;
• Large or unusual single deposits or withdrawals are made;
• Inconsistencies are identified between declared and actual sources of funds;
• The customer triggers an internal risk flag at any stage of the relationship.

Where EDD is applied, we may request additional documentation and information including, but not limited to:

• Source of funds documentation (e.g. payslips, bank statements, tax returns, dividend records);
• Source of wealth documentation (e.g. evidence of business ownership, inheritance, property sale proceeds);
• Details of employment or business activities;
• Enhanced screening against PEP, sanctions, and adverse media databases;
• Senior management approval before processing certain transactions.

8. PEP and Sanctions Screening

All customers are screened at registration and on an ongoing basis against:

• International PEP databases;
• United Nations, European Union, OFAC, and other relevant sanctions lists;
• Adverse media and financial crime watchlists.

Where a customer is identified as a PEP, or as being subject to applicable sanctions, Kassabet Casino will apply EDD as a minimum. Accounts belonging to individuals who are subject to international sanctions will not be opened or will be suspended immediately upon identification, and the matter will be escalated to the MLRO.

9. Transaction Monitoring

Kassabet Casino maintains ongoing monitoring of all customer transactions and account activity. Our transaction monitoring programme is designed to identify patterns or behaviours that may be inconsistent with legitimate gambling activity or that may indicate an attempt to use kassa-bet.com for money laundering or other financial crime. Monitored indicators include, but are not limited to:

• Rapid cycling of funds — depositing and withdrawing without significant gameplay;
• Structuring of deposits or withdrawals to avoid thresholds;
• Use of multiple payment methods without a clear rationale;
• Sudden and unexplained increases in deposit or wagering volumes;
• Requests to withdraw to a payment method different from the one used to deposit;
• Patterns of play that appear designed to generate a withdrawal entitlement rather than for recreational gambling;
• Inconsistencies between declared account information and observed behaviour;
• Activity from IP addresses or devices associated with high-risk jurisdictions or previously flagged accounts.

Where suspicious activity is identified, the matter is escalated internally to the MLRO for review. Depending on the outcome of that review, a SAR may be filed with the relevant authorities and the account may be suspended pending investigation.

10. Withdrawal Limits and Financial Controls

Kassabet Casino applies the following financial limits to all customer accounts, which form part of our broader AML controls framework:

These limits apply by default to all accounts. Requests to exceed these limits may require additional KYC or EDD documentation, including source of funds and source of wealth evidence, prior to processing. Kassabet Casino reserves the right to decline or delay any transaction that cannot be satisfactorily explained or verified.

11. Payment Method Restrictions

The following rules apply to all payment transactions at kassa-bet.com:

• All deposits must be made from a payment account held in the customer's own name. Third-party payments are strictly prohibited.
• Withdrawals will be made to the same payment method used to make deposits wherever possible, in accordance with anti-money laundering best practice.
• Where a withdrawal to the original deposit method is not possible, the customer will be required to provide satisfactory evidence of ownership of the alternative account before the withdrawal is processed.
• Accepted payment methods at kassa-bet.com include Visa, Mastercard, Visa Electron, Maestro, Apple Pay, Revolut, and cryptocurrency. The specific methods available to any given customer may vary based on jurisdiction and account status.
• Cryptocurrency transactions are subject to additional verification, including wallet ownership confirmation, and may require blockchain transaction records as part of the KYC process.

12. Age Verification

Kassabet Casino does not permit gambling by persons under the age of 18. Age verification is a mandatory component of our KYC process. Where we are unable to confirm that a customer is aged 18 or over, the account will be restricted until satisfactory proof of age is provided. Any funds deposited by a person subsequently found to be underage will be returned, and no winnings generated during the period of underage access will be paid out. We may report underage gambling to the relevant authorities where legally required to do so.

13. Responsible Gambling and AML Interaction

Kassabet Casino recognises that problem gambling behaviours can sometimes present indicators similar to those associated with financial crime — including erratic deposit patterns, requests to withdraw funds shortly after deposit, and sudden changes in wagering activity. Our compliance and responsible gambling teams work in conjunction to identify and respond to these patterns appropriately.

Customers who wish to set limits on their deposits, losses, or session times, or who wish to self-exclude, are encouraged to contact our support team at any time via 24/7 live chat or by email. Responsible gambling tools are available directly through the customer account area at kassa-bet.com. The availability of these tools does not affect or limit our obligations under this AML/KYC Policy.

14. Suspicious Activity Reporting

Where Kassabet Casino identifies activity that gives rise to a suspicion of money laundering, terrorist financing, or other financial crime, the following internal process applies:

• The relevant team member identifies and documents the concern and reports it internally to the MLRO without delay;
• The MLRO reviews the report and determines whether a SAR should be filed with the relevant authority;
• The account in question may be suspended pending the outcome of the MLRO's review;
• No person at Kassabet Casino will "tip off" a customer that they are under suspicion or that a report has been made;
• Kassabet Casino will cooperate fully with any investigation conducted by competent authorities and will produce records as lawfully required.

15. Record Keeping

Kassabet Casino retains all KYC documentation, transaction records, account histories, and compliance-related communications for a minimum of five years from the date of the relevant transaction or the closure of the account, whichever is later. Records are stored securely and in accordance with our Privacy Policy. They may be made available to competent authorities upon lawful request.

16. Staff Training and Internal Controls

All personnel involved in the operation of kassa-bet.com who have contact with customers or financial data are required to receive appropriate AML/KYC training. This training covers:

• Recognition of suspicious activity and financial crime typologies;
• The internal escalation and SAR reporting process;
• Customer due diligence procedures and documentation standards;
• Obligations relating to tipping off and confidentiality;
• Applicable regulatory requirements under the Anjouan Gaming Board licence.

Training is conducted at induction and refreshed on a regular basis, or whenever material changes to this Policy or the applicable regulatory framework occur. The MLRO is responsible for maintaining records of training completion.

17. Non-Cooperation and Account Closure

Where a customer refuses to provide requested KYC documentation, provides documentation that cannot be verified, provides false or misleading information, or otherwise fails to cooperate with our compliance obligations, Kassabet Casino reserves the right to:

• Suspend access to all or part of the account;
• Withhold pending withdrawals pending satisfactory resolution;
• Permanently close the account;
• Retain funds where required to do so by law or by order of a competent authority;
• File a SAR with the relevant authority as appropriate.

Any decision to close an account or withhold funds will be communicated to the customer in writing unless we are legally prohibited from doing so.

18. Prohibited Jurisdictions

Kassabet Casino does not knowingly accept customers from jurisdictions where online gambling is prohibited by local law, or from jurisdictions that are subject to comprehensive international sanctions. It is the customer's responsibility to ensure that their participation at kassa-bet.com is lawful in their country of residence. We reserve the right to refuse or close accounts from any jurisdiction at our sole discretion, in accordance with our legal and regulatory obligations.

19. Policy Review

This AML/KYC Policy is reviewed at least annually and updated as necessary to reflect changes in applicable law, regulatory guidance, or the internal risk profile of Kassabet Casino. The current version of this Policy is always available at kassa-bet.com. Continued use of the platform following any material update constitutes acceptance of the revised Policy.

20. Contact and Escalation

If you have any questions regarding this Policy, your KYC status, or a verification request you have received, please contact our support team:

• Live chat: available 24/7 directly at kassa-bet.com
• Email: available via the contact page at kassa-bet.com

For compliance-related escalations, correspondence may also be directed to the MLRO via the above contact channels, marked for the attention of the Compliance Department. Kassabet Casino is committed to responding to all compliance-related enquiries promptly and in good faith.