This AML/CFT Policy establishes the framework by which 5bb5 identifies, assesses and manages money-laundering and terrorism-financing risks in relation to all customers and transactions. It applies to all individuals and parties engaging with 5bb5, and governs customer due diligence, ongoing monitoring, record-keeping, reporting, and escalation procedures in accordance with applicable laws and supervisory guidance relevant to the Company's licensing regime.
The Board of Directors bears ultimate responsibility for AML compliance. An Anti-Money Laundering Compliance Officer (AMLCO) is appointed to oversee day-to-day implementation and reports directly to senior management. The Money Laundering Reporting Officer (MLRO) maintains responsibility for reporting suspected ML/CTF activity to the appropriate authorities. Material amendments to this Policy require approval from the Board and the AMLCO/MLRO prior to implementation.
5bb5 shall review this Policy at least annually or more frequently if changes in law, regulatory guidance or risk posture warrant. All material revisions require formal approval by the Board and the AMLCO/MLRO and must be communicated to staff with appropriate training updated accordingly.
5bb5 operates a risk-based, tiered KYC model. Verification requirements scale with the assessed risk and transaction activity. The tiers, triggers and limits are as follows:
Verification steps may include electronic data enrichment and third-party checks. If verification fails or discrepancies cannot be resolved, 5bb5 may restrict or terminate access to services until concerns are resolved.
Address verification is obtained via two independent electronic or physical sources. Acceptable documents dated within the last three months include utility bills, bank or card statements, or official government correspondence. Documents must clearly display the customer name and current address, be legible in Latin characters, and show the issuing date.
5bb5 may request evidence that funds used for gaming activities originate from lawful activity at any time. Acceptable evidence includes employment payslips, bank statements, tax documents, inheritance records, and investment statements. Where reasonable explanations are not provided, 5bb5 may suspend or terminate the relationship or impose additional verification steps.
5bb5 adopts a risk-based approach to ongoing monitoring, transaction screening and due diligence. The risk framework considers customer type, product usage, geography, transaction patterns and device/IP information. 5bb5 may initiate additional due diligence or restrict access without prior notice where risk indicators, including geolocation to high-risk jurisdictions or sanctions, are identified. All unusual or suspicious activity is subject to escalation under the MLRO process and may result in temporary freezing of funds or blocking of accounts pending investigation.
Customer identification records are retained for a minimum of six (6) years after the termination of the customer relationship. Transaction records are retained for a minimum of ten (10) years after the date of transaction or account closure. All records shall be securely stored in encrypted form and retrievable for regulatory or law-enforcement inquiries.
5bb5 applies robust technical and organizational controls to protect personal data, including access controls, encryption in transit and at rest, and secure multi-layer storage. Data may be disclosed only with explicit customer consent, as required by law, or to comply with AML/CFT obligations. The Company adheres to applicable data-protection requirements and maintains a commitment to information security standards commensurate with risk.
Employees must report grounds for knowledge or suspicion of money laundering, or financing of terrorism, to the MLRO. Reports (SARs) are to be conducted confidentially and without disclosure to the subject of the investigation. Any disclosure that could prejudice an investigation is strictly prohibited. The escalation process requires prompt action; failure to report may result in criminal or regulatory liability.
5bb5 provides ongoing AML/CFT training to all relevant staff, covering customer due diligence, enhanced due diligence for high-risk clients (including PEPs where applicable), regulatory reporting obligations, and internal escalation procedures. Training emphasizes accountability and the legal implications of non-compliance.
Customers located in or transacting from high-risk jurisdictions, or from countries subject to sanctions, are subject to Enhanced Due Diligence and, where appropriate, restricted or terminated relationships. 5bb5 aligns with FATF guidance and the requirements of the competent regulator to identify and respond to jurisdictional risk.
All staff implicated in AML controls undergo vetting for age, identity and background. Access to AML-sensitive systems is restricted on a need-to-know basis and requires appropriate authentication and authorization. Violations of AML duties by employees may lead to disciplinary action, including termination and referral for prosecution where warranted.
5bb5 maintains an AML/Risk Compliance Committee comprising the MLRO, the AMLCO and an independent director where feasible. The Committee reviews the effectiveness of controls, audits, and regulatory changes, meeting at least quarterly or as required by risk posture.
This Policy operates under the applicable AML/CFT laws and regulatory framework governing 5bb5. For questions regarding this Policy, contact the designated AML team within 5bb5. All inquiries will be handled in accordance with internal data-protection and privacy requirements.
