AML Policy

1. Introduction

必贏娛樂城 (hereinafter referred to as “we,” “the Company,” or “必贏娛樂城”), as a globally recognized and trusted gaming business entity, strictly opposes, prohibits, and refuses any illegal use of its platform and services, including but not limited to money laundering, terrorist financing, and other forms of financial crime. We are committed to complying with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and regulations, ensuring safe and transparent operations in line with international standards.

2. What Are Money Laundering and Terrorist Financing?

Money Laundering: Money laundering refers to the process by which an individual or entity disguises the illicit origin of funds obtained through criminal activity so that they appear legitimate. Money laundering typically involves three stages: (1) Placement: introducing illicit funds into the legitimate financial system; (2) Layering: using complex and opaque transactions to obscure the source of funds and make tracing more difficult; (3) Integration: reintroducing funds into the economy so they appear as legitimate assets or income. Terrorist Financing: This refers to raising, providing, or transferring funds to directly or indirectly support terrorist activities.

3. How Do We Address Money Laundering and Terrorist Financing?

必贏娛樂城 has implemented a comprehensive AML/CTF compliance program covering the following key areas: (1) Internal Policies and Procedures
We establish and regularly update internal policies designed to detect, prevent, and report suspicious activities. (2) Know Your Customer (KYC)
We apply strict KYC procedures to verify user identity and source of funds, ensuring there is no involvement in illegal activities. (3) Transaction Monitoring
We use advanced systems to monitor transactions in real time and proactively identify and investigate suspicious behavior. (4) Governance and Staff Training
All employees receive AML/CTF compliance training to build risk awareness and strengthen accountability. (5) Statutory Reporting Obligations
Where suspicious activities are identified, we will report them to the competent authorities as required by law and cooperate fully with investigations. (6) Restricted Jurisdictions
Users residing in restricted jurisdictions listed in the Terms of Service are prohibited from accessing the platform to safeguard compliance and risk control. Activities originating from such jurisdictions will be flagged and reported in accordance with applicable laws. Through these measures, 必贏娛樂城 is committed to maintaining platform integrity and actively supporting global efforts to combat financial crime.

4. Know Your Customer (KYC)

必贏娛樂城 applies the following strict KYC and due diligence measures: (1) Identity Verification
We verify a player’s name, date of birth, and address by collecting official documents such as a passport or driver’s license. (2) Politically Exposed Person (PEP) and Sanctions Screening
We screen whether a player is a PEP or appears on international sanctions lists to mitigate risks associated with high-risk individuals. (3) Source of Funds Checks
Where necessary, we may require users to provide proof of income or source of wealth to confirm the legitimacy of funds used for betting. (4) Notification and Grace Period
If KYC is not completed, we will notify the user by email and provide a 14-day grace period. Failure to comply within the period may result in account suspension or closure. 必贏娛樂城 reserves the right to request additional documents or conduct enhanced reviews, particularly when fraud or high-risk events are detected.

5. Enhanced Due Diligence (EDD)

For the following high-risk scenarios, we implement EDD measures: (1) Identifying High-Risk Customers

• Residents of jurisdictions classified as high risk by FATF or other relevant bodies; • Politically Exposed Persons (PEPs) and their relatives or close associates; • Customers conducting high-value or unusual transactions. (2) Collecting Additional Information

• Detailed source of funds and source of wealth; • Recent proof of income or assets; • Notarized identity documents or proof of address. (3) Ongoing Monitoring

• Real-time monitoring of transactions for high-risk accounts; • Periodic review and updates of KYC information; • Immediate reporting of suspicious activities to the MLRO. (4) Senior Management Approval
High-risk accounts require approval by a senior compliance officer or management before services may continue. (5) Record Retention
All EDD documentation will be retained for at least 10 years in accordance with applicable laws and to support regulatory investigations.

6. Transaction Monitoring

必贏娛樂城 uses an advanced system combining AI tools and manual review to implement the following measures: (1) Detecting abnormal transaction patterns; (2) Flagging high-risk behavior for deeper analysis; (3) Reporting confirmed suspicious transactions to the relevant competent authorities as required by law. We continuously update our systems to address emerging fraud patterns and compliance changes.

7. Governance and Training

The Company has appointed a Money Laundering Reporting Officer (MLRO) responsible for: (1) Ensuring operations comply with AML/CTF requirements; (2) Continuously revising and optimizing internal compliance processes; (3) Investigating and reporting suspicious activities; (4) Regularly auditing the effectiveness of AML controls. Employees must complete mandatory AML/CTF training annually to foster a compliance culture and strengthen risk sensitivity.

8. Addressing Emerging Threats

必贏娛樂城 closely monitors evolving risks related to money laundering and terrorist financing, especially the misuse of cryptocurrencies: (1) Tracking suspicious on-chain fund flows; (2) Deploying blockchain analytics tools; (3) Cooperating with international regulators to stay aligned with the latest rules and technical standards.

9. Cooperation with Competent Authorities

We maintain close collaboration with law enforcement agencies globally to ensure: • Timely submission of legally required reports; • Active assistance in investigations concerning money laundering, terrorist financing, and illegal financial activities; • Protection of platform integrity and the broader financial ecosystem.

10. Periodic Review

必贏娛樂城 regularly reviews its AML/CTF program to ensure: (1) Ongoing compliance with the latest laws and regulatory standards; (2) Continued effectiveness of policies and operating procedures; (3) Flexibility to respond to emerging financial risks and market developments.