WinWin KYC & AML Policy

KYC and AML procedures are applied to confirm the identity of each account holder, prevent fraud, and support responsible gaming in a manner consistent with Bangladeshi regulatory requirements. These measures also assist in transaction monitoring and protection against the misuse of the platform for illegal purposes.

The KYC and AML framework aims to support:

• Fair play for all users through verified identity and controlled access
• User safety through strong account protection and security measures
• Transparency about how personal data is used for identity check and ID verification
• Compliance with applicable regulatory requirements and reporting obligations in Bangladesh
• Prevention of financial abuse, including money laundering and terrorism financing

Every new user must complete ID verification so that the platform can confirm personal data, verify age, and ensure that the person opening the account is the genuine account holder. Additional KYC checks may be requested at any time during the user relationship, including before deposits, withdrawals, or where transaction monitoring identifies unusual or suspicious activity.

As part of document submission, the platform may request the following categories of information:

• A valid government-issued photo identification document (for example, passport, national identity card, or driving licence), to confirm identity and date of birth
• Proof of address showing the user’s full name and residential address (for example, recent utility bill, bank statement, or official letter), to confirm place of residence in Bangladesh or another relevant jurisdiction
• Evidence of ownership for payment instruments used on the account (for example, bank card in the same name, bank account statement, mobile financial service statement), to confirm that only payment methods belonging to the account holder are used
• Any additional information or documentation necessary to clarify the source of funds or source of wealth where required by AML and CTF rules

The platform applies structured AML controls and security measures to prevent money laundering, terrorism financing, and other illegal financial activity. These controls support ongoing transaction monitoring, rapid detection of suspicious activity, and compliance with Bangladeshi reporting obligations.

Core AML measures include:

• Continuous monitoring of user transactions and gameplay patterns to identify unusual betting, deposits, or withdrawals
• Automated detection rules and risk models designed to highlight inconsistent behaviour, high-risk transaction flows, or attempts to bypass identity check requirements
• Enhanced due diligence for high-risk users, complex cases, or when large or unusual payments occur
• Regular review and investigation of significant transfers, rapid turnover of funds, or other activity that may indicate money laundering
• Assignment and adjustment of risk scoring for accounts, reflecting user profile, transaction history, and geography
• Screening of users against relevant sanctions lists and politically exposed person (PEP) lists as required by applicable regulatory requirements in Bangladesh
• Timely reporting of suspicious activity or suspect transactions to competent authorities where this is required by law and regulatory reporting obligations

Certain behaviours are not allowed on the platform because they undermine identity check, document submission integrity, and AML safeguards. Users must avoid any activity that may conceal the true identity of the account holder, disguise the source of funds, or interfere with security measures aimed at user safety.

Prohibited activities include:

• Opening or operating multiple accounts for the same person, or acting as a front for other individuals
• Submitting forged, altered, or stolen identification documents or proof of address
• Using the platform to attempt money laundering, terrorism financing, or movement of criminal proceeds
• Manipulating systems, exploiting technical vulnerabilities, or using automated tools to influence transactions or gameplay outcomes
• Sharing, selling, or transferring account access, login details, or control of the account to any third party
• Using payment instruments, bank accounts, or mobile financial service wallets that do not belong to the verified account holder
• Misrepresenting identity, providing false personal data, or concealing the connection between the user and the funds being used

Failure to comply with KYC and AML rules, refusal to complete ID verification, or involvement in suspicious activity may lead to enforcement actions under this policy and applicable Bangladeshi law. These steps are necessary to protect user safety, meet regulatory requirements, and uphold fair play and transparency.

In case of non-compliance, measures can include temporary or permanent account suspension, freezing or confiscation of funds linked to suspicious activity, cancellation of bets or winnings, reporting to competent authorities where applicable.

Users are responsible for providing accurate and complete personal data during registration and throughout the lifetime of the account, including prompt updates when details such as address, document numbers, or payment information change. All requests for identity check, ID verification, and document submission must be completed within the timeframe communicated by the platform so that regulatory requirements can be met. Users must respond to any follow-up questions or additional documentation requests that arise from transaction monitoring or reviews of suspicious activity. Only payment methods owned and controlled by the account holder may be used, and access credentials must be kept secure at all times to support account protection. Any suspected unauthorised access, potential misuse of funds, or security incident should be reported immediately through the available support channels so that appropriate security measures can be taken.

The platform is committed to fair play, transparency, and responsible gaming so that every account holder in Bangladesh can participate in a controlled and secure environment. KYC, AML, and related security measures are applied consistently to protect users, promote user safety, and reduce the risk of suspicious activity affecting the gaming experience.

These commitments are based on the following principles:

• Full alignment of identity check, ID verification, and transaction monitoring practices with applicable KYC and AML standards
• Protection of personal data through confidentiality safeguards, secure storage, and restricted access based on regulatory requirements
• Ongoing monitoring of transactions and behaviour to identify and act on potential suspicious activity in a timely manner
• Prevention of manipulation, unfair behaviour, and use of the platform for any purpose that conflicts with responsible gaming
• Dedicated user support for queries related to account protection, document submission, and safety concerns
• Shared responsibility, where both the platform and users cooperate to maintain a compliant and secure environment
• Equal terms and conditions for all users, ensuring that AML controls, reporting obligations, and enforcement actions are applied consistently and without favour