Aml Policies

Purpose and Scope

The Anti‑Money Laundering Policy (the Policy) sets forth Swiss4win’s measures to prevent, detect and report money laundering and the financing of terrorism in relation to its online gambling services. The Policy applies to all customers, accounts, devices, payments and transactions conducted on Swiss4win platforms, including Prematch and Live betting activities, and remains in effect while an account is active or during any interacting obligations with Swiss4win.

Regulatory Framework and Core Principles

Swiss4win operates in compliance with applicable law, including EU and national AML/CFT regulations and relevant data protection standards. The Policy adopts a risk‑based approach consistent with international standards such as the Financial Action Task Force (FATF) guidance. Where required by law, Swiss4win aligns with the General Data Protection Regulation (GDPR) and equivalent data protection regimes to safeguard personal data collected under this Policy.

Risk-Based Approach

Swiss4win conducts ongoing risk assessment to identify and mitigate ML/TF risks. Risk factors include customer geography, customer activity patterns, and the nature of the gaming or payment activities. The Company documents risk findings and applies proportionate controls to high‑risk scenarios, with escalation to the compliance function for enhanced actions when warranted.

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

Swiss4win employs CDD for account opening and ongoing monitoring. Standard verification is triggered when customer activity reaches defined thresholds, and additional measures may be applied for elevated risk profiles.

• Trigger for Standard Verification: When the total amount of transactions conducted by a user reaches or exceeds USD 1,000 (or the equivalent in another currency), Standard Verification is initiated.
• Documentation Required (Verification Pack):
  • A clear, legible copy or photograph of a government‑issued photo identity document (passport, national ID, or other approved document).
  • Proof of residential address (e.g., utility bill, bank statement) dated within a reasonable period prior to verification.
  • A current photograph of the user holding the identification document when required by internal procedures.
  • A photograph of the payment card intended for use, showing the cardholder name as it appears on the account; the card’s first six and last four digits may be visible, with full CVV suppressed or hidden in accordance with applicable privacy standards.
  • A photograph of the user, displaying the required documents, plus any additional documents demanded by local regulatory requirements (e.g., proof of source of funds or income, as applicable).
  • In certain circumstances, the user may be asked to connect with Swiss4win Support via a secure channel (phone or video) for identity verification.
• Enhanced Due Diligence (EDD): For Politically Exposed Persons (PEPs), family members of PEPs, or users located in high‑risk jurisdictions, Swiss4win applies enhanced verification and additional data as required by law and regulatory expectations. This may include source of wealth documentation and more frequent review.
• Recordkeeping: Verification materials are stored and protected in accordance with GDPR and applicable law. Access is restricted to authorized personnel in the compliance function.

Ongoing Monitoring and Activity Audits

Swiss4win conducts continuous activity monitoring to identify suspicious patterns and anomalous behavior. Monitoring focuses on maintaining the integrity of wagering activities, payments and the overall platform risk posture.

• Indicators of suspicious activity include abnormal deposit patterns, multi‑device or multi‑account usage, geographic inconsistencies, and reluctance to complete verification.
• The antifraud team investigates suspicious activity and directs findings to the relevant departments for action, including escalation to senior management when necessary.

Transaction Monitoring and Payment Integrity

All financial transactions are monitored for compliance with this Policy. Swiss4win enforces strict controls to ensure payments are attributable to the account holder and are not used for illicit purposes.

• Name Matching: When a payment card is used, the cardholder name must match the account holder’s name. Third‑party card usage is prohibited.
• Wallets and Email: For electronic wallets, the wallet email must correspond to the account email registered with Swiss4win.
• Withdrawal and Deposits Alignment: Withdrawals are only made to funds sources that can be reliably linked to the user. If funds originate from an instrument with withdrawal restrictions or if funds cannot be traced, Swiss4win will direct the withdrawal to an approved instrument or require further verification.
• Prohibition on Anonymous Instruments: The Company does not accept payments from anonymous payment instruments and does not withdraw funds to third‑party accounts.

Record‑Keeping, Data Management and Retention

Swiss4win preserves documentation and transactional data in accordance with applicable AML/CFT and data protection laws, including GDPR. Records will be retained for a period required by law or as reasonably necessary for the purposes of compliance, investigations, and regulatory reporting.

Suspicious Activity Reporting and Regulatory Cooperation

Swiss4win has a defined process to report suspicious activities to the appropriate authorities as required by law. Where the Company has credible grounds to suspect improper activity or non‑compliance, it will escalate the matter to the antifraud/compliance team and, if needed, notify relevant regulatory or governmental authorities in accordance with regulatory obligations.

Amendments and Communications

This Policy may be amended or updated by Swiss4win at any time to reflect changes in law, regulation or risk posture. Registered users will be notified of material changes by secure channels and continued use of the platform after notification constitutes consent to the updated Policy.

Governance, Roles and Training

Swiss4win assigns responsibility for AML/CTF compliance to a designated Compliance Function. The antifraud department conducts investigations and, where appropriate, elevates issues to senior management for final decisions. Ongoing training and awareness programs are maintained for staff to ensure effective policy implementation.

Definitions and Contact

For purposes of this Policy, terms such as “money laundering,” “terrorist financing,” “PEP,” and “high‑risk jurisdiction” carry the meanings given in applicable AML/CFT laws and regulatory guidance. For questions related to this Policy or requests for verification, users may contact Swiss4win Compliance through secure channels provided within the account management interface.