Anti-money Laundering Policy

Purpose and scope

This Anti-Money Laundering (AML) Policy establishes the controls implemented by Rkgg to prevent money laundering and the financing of terrorism in connection with all gaming activities and related financial transactions conducted through Rkgg platforms. It governs the identification, verification, ongoing monitoring, record keeping, and reporting obligations applicable to all customers, operations, and personnel under Rkgg.

Legal basis and regulatory context

Rkgg operates in accordance with applicable AML/CTF laws and licensing requirements. This policy is designed to satisfy statutory obligations and reflect recognized industry practices, while maintaining compliance with the licensing regime under which Rkgg operates. All measures herein are applied without discrimination to ensure lawful conduct of gaming and financial activities.

Governance and risk-based approach

Rkgg applies a risk-based framework to identify, assess, and mitigate money laundering and terrorist financing risks. The Compliance Officer, reporting to the board or equivalent governing body, is responsible for implementing the programme, allocating resources, and ensuring controls are proportionate to the risk profile of customers, products, services, and geographies. Regular senior management reviews are conducted to assess effectiveness and approve material changes.

Know Your Customer (KYC) and Customer Due Diligence (CDD)

Rkgg conducts KYC and due diligence on all customers prior to enabling full service or prior to processing significant transactions. The standard due diligence process includes collection and verification of identifying information, address, and proof of identity, together with information sufficient to determine customer legitimacy and risk. Documentation may include government-issued photo ID, proof of address, and a self-portrait holding the ID. Verification steps are proportionate to risk and may require additional sources of information when necessary.

Risk categorization: SDD, CDD and EDD

Rkgg employs a three-tier due diligence model based on the assessed risk of the customer and transaction. Simplified due diligence (SDD) applies to extremely low-risk scenarios. Customer due diligence (CDD) applies to standard-risk customers and transactions. Enhanced due diligence (EDD) applies to high-risk customers, large-value transactions, or special cases requiring intensified verification and ongoing monitoring. Risk assessments are reviewed periodically and updated upon material changes in customer profile or activity.

Triggers for enhanced due diligence and KYC escalation

Beyond ongoing monitoring, specific thresholds or events will trigger heightened KYC measures. Notably, when a customer’s aggregate lifetime deposits reach or exceed EUR 5,000, or the customer initiates or completes a withdrawal request, Rkgg will enforce full KYC remediation. In such cases, additional documentation and verification steps may be required, and access to certain features may remain restricted until verification is complete.

Ongoing monitoring and screening

Rkgg conducts continuous monitoring of customer activity and transactions using risk-based rules. Transactions that exhibit unusual patterns, rapid movements, inconsistent sources of funds, or links to high-risk geographies are flagged for review. Sanctions screening and adverse media checks are performed on new and existing customers at defined intervals or upon material changes in risk profile.

Record keeping and data protection

Rkgg maintains records of customer identity, verification documents, transaction data, and KYC files for not less than five years from the date of the last activity or account closure, in a secure and accessible manner for internal audit and regulatory purposes. Access to personal data is restricted to authorized personnel and processed in accordance with applicable data protection laws and internal privacy policies.

Suspicious activity reporting and cooperation with authorities

Rkgg has an obligation to report suspicious activities and transactions to the appropriate competent authorities in accordance with applicable law. Any report, investigation, or inquiry will be conducted in a manner that preserves the integrity of the information and protects the confidentiality of the reporting process. Rkgg cooperates with law enforcement and regulators and will provide information and assistance as required, subject to applicable privacy and legal constraints.

Account controls, restrictions and withdrawal procedures

If identity verification or KYC checks are incomplete, incomplete due diligence exists, or heightened risk is identified, Rkgg may restrict deposits, limit or delay withdrawals, or suspend account activity. Full withdrawal rights are conditioned on successful verification and complete compliance with KYC requirements. Ongoing verification may be requested at any time to confirm identity, residence, or ongoing eligibility for services.

Training, governance, and policy review

Rkgg provides mandatory AML training to all staff with annual refreshers. The AML policy, including related procedures, is reviewed at least annually or in response to material regulatory change, with amendments approved by the Compliance Committee and communicated to relevant personnel.

Definitions

For the purposes of this policy, the following terms have the meanings set out below: Money laundering means the process of disguising the origins of illegally obtained funds to make them appear legitimate. Terrorist financing refers to the solicitation, collection, or transfer of funds intended to support extremist causes, regardless of the origin of the funds. Know Your Customer (KYC) is the process of identifying and verifying customers, assessing risk, and ongoing monitoring. Customer Due Diligence (CDD) is standard verification and monitoring for normal-risk customers. Simplified Due Diligence (SDD) applies to very low-risk cases with reduced verification requirements. Enhanced Due Diligence (EDD) is intensified verification and monitoring for high-risk cases. Aggregate lifetime deposits refers to the cumulative total of deposits by a customer over the lifetime of the relationship with Rkgg. All other terms used herein shall have their ordinary, statutory meanings consistent with applicable AML/CTF laws.