Kyc Policies

Purpose and Scope

Rkgg maintains a Know Your Customer KYC policy to identify customers assess financial crime risk and monitor transactions on a risk based basis in accordance with applicable laws and regulations. This policy applies to all users accessing Rkgg services including gaming payments and withdrawals and governs onboarding verification ongoing monitoring data collection and reporting.

Definitions

  • CDD customer due diligence standard verification procedures appropriate to identified risk
  • EDD enhanced due diligence for higher risk customers or complex transactions
  • SDD simplified due diligence for extremely low risk activity
  • MLRO money laundering reporting officer responsible for anti money laundering compliance
  • SAR suspicious activity report or any report of suspected ML or CTF activity
  • High Risk Jurisdiction jurisdictions identified as high risk by regulators or by Rkgg risk assessment

Risk Based Framework

Rkgg employs a risk based approach to KYC. Customer risk is assessed at onboarding and during ongoing activity. The level of verification monitoring and potential restrictions is determined by the assessed risk and the nature of the transactions.

Identity Verification and Documentation

Onboarding requires verification of identity with the following documentation unless a risk based exemption applies:

  • Government issued photo ID such as a passport national identity card or driver license. The document must be valid and the name must match the customer account
  • Proof of address showing the customer name and current residential address issued within the last three months such as a utility bill or bank statement
  • A live selfie of the customer holding the issued ID to confirm identity

Notes on submission and review

  • Verification documents are reviewed within three business days of receipt. If additional information is required the customer will be notified and a timeline will be provided
  • Documents that fail to meet requirements will be rejected with clear explanation and guidance for remediation

Trigger Events and Verification Stages

Rkgg uses three due diligence levels based on risk assessment:

  • SDD for extremely low risk activities
  • CDD for standard gaming and payments
  • EDD for high risk customers or transactions including complex ownership structures

Key triggers for full KYC include aggregate deposits across the account reaching or exceeding a threshold such as EUR 5 000 over the customer lifetime or initiating a withdrawal after significant activity. Additional triggers may include unusual patterns or refined risk indicators flagged by monitoring systems.

Ongoing Monitoring and Review

Rkgg conducts ongoing monitoring of customer transactions updating risk profiles as new information becomes available. Customer risk assessments are reviewed at least annually and whenever material changes in circumstances occur.

Enhanced Due Diligence and Source of Funds

For high risk customers or large value transactions Rkgg requires enhanced information including source of funds and source of wealth documentation plus details about employment and beneficial ownership. Acceptable documentation may include bank statements payslips tax returns and corporate records as applicable.

High Risk Jurisdictions

Rkgg identifies high risk or restricted jurisdictions and applies enhanced controls. Customers located in or connected with such jurisdictions are subject to enhanced due diligence or may face transaction restrictions. The list includes jurisdictions identified by regulators as high risk for money laundering or financing of terrorism and other jurisdictions designated by Rkgg as high risk from time to time.

Record Keeping and Data Retention

Rkgg maintains a complete audit trail of customer identification verification risk assessments monitoring activities and SARs. Records related to KYC are retained for a minimum of five years after the end of the customer relationship or longer as required by applicable law and regulatory guidance.

Data Privacy and Security

Personal data collected under this policy is processed lawfully fairly and securely in accordance with applicable data protection law. Data is stored with appropriate security controls and customers retain rights to access rectify erase or constrain processing where permitted by law.

Roles and Governance

The designated MLRO leads KYC risk management and compliance. The Compliance Officer and senior management oversee policy implementation and reporting. All staff undertake AML and KYC training at onboarding and receive periodic updates aligned with regulatory developments.

Suspicious Activity Reporting

Employees must report grounds for knowledge or suspicion of money laundering or terrorist financing to the MLRO. The MLRO reviews reports and when warranted files a SAR with the competent authorities. Disclosure to customers or other persons regarding an investigation is strictly prohibited until approved by the appropriate authorities.

Account Restrictions and Onboarding Outcomes

Until verification is complete or further information is required, Rkgg may restrict account activity including deposits and withdrawals. Verification completion results in approval subject to ongoing monitoring and potential further due diligence as needed.

Customer Support and Contact

Queries regarding KYC procedures may be directed to Rkgg compliance channels. Information collected for KYC is kept confidential and used solely for AML KYC purposes in accordance with applicable law.