67mxn (the Company) adopts comprehensive Know Your Customer (KYC) and anti‑money laundering (AML) controls to prevent misuse of its gaming services. The policy applies to all customer onboarding, ongoing activity, payments, and account management conducted through the Company’s platforms, including any affiliate or partner channels that process customer data on behalf of the Company. The policy extends to all jurisdictions in which the Company operates, to the fullest extent permitted by law, and governs all employees, contractors, and representatives involved in onboarding, verification, monitoring, and reporting.
On onboarding, the Company shall identify the customer and verify the customer’s identity prior to providing services. The verification process includes collection of: full legal name, date of birth, current residential address, nationality, and a non‑expired government‑issued document containing a photograph (passport, national ID card, or other approved document). Where necessary, additional verification may be performed by live video verification, biometric validation, or cross‑checks with geolocation data, device fingerprints, or third‑party identity data providers. The customer must be of legal age to participate, and the Company shall document the basis for age verification. If documentation is unavailable, the Company may refuse account creation or suspend activity until verification is completed.
The Company adopts a risk‑based approach to CDD. The level of due diligence depends on the customer’s risk profile, transaction type, and channel. Triggering conditions for CDD include: a) onboarding of new customers; b) occasional transactions equal to or exceeding the equivalent of 4,000 currency units; c) changes in risk status or ownership structure; d) suspicious activity or inconsistent information.
CDD measures include: verifying source of funds and, where necessary, source of wealth; obtaining documentation (e.g., bank statements, payslips, tax documents) to support the stated source of funds; ongoing monitoring of transactions and behavioral patterns; and maintaining a dynamic risk rating for each customer (low, medium, or high).
EDD applies when the customer, product, channel, or geography presents higher ML/TF/PF risk. EDD requirements include additional identity verification, scrutiny of beneficial ownership, verification of the origin of funds with independent corroboration, enhanced transaction monitoring, and periodic reviews of the customer relationship. Decisions on EDD are approved by senior management and recorded with a rationale and supporting data.
All customers undergo sanctions and PEP screening prior to onboarding and on an ongoing basis. Screening includes local and international sanctions lists and reputable risk databases. If a customer is identified as a PEP or subject to sanctions, the Company requires senior management approval, verification of the source of funds, and the application of enhanced monitoring. The Company may decline or terminate a relationship where sanctioned status, lack of funds verification, or fraudulent documentation is detected.
Customers must provide a credible source of funds for deposits and a clear explanation of the customer’s typical income streams. For higher risk profiles, documentation supporting the source of funds and, where appropriate, source of wealth shall be obtained and validated. The Company reserves the right to request additional information to satisfy risk assessments and regulatory obligations.
The Company shall identify and verify beneficial owners to the extent required by applicable law. For legal entities, beneficial ownership is determined by individuals with 25% or more ownership or effective control, or as otherwise defined by law. Documentation supporting ownership and control structures shall be retained and reviewed periodically.
Customer activity and risk profiles are monitored continuously. The Company reviews high‑risk accounts and any unusual or suspicious transactions promptly and adjusts the customer’s risk rating and due diligence requirements as needed. Ongoing monitoring includes transaction pattern analysis, amendments to personal data, and periodic re‑verification of identity as warranted by risk indicators.
The Company retains all KYC/CDD/EDD records, monitoring data, and related documentation for a minimum period of five years after the end of the customer relationship, or longer if required by applicable law. Records shall be maintained in a secure, access‑controlled environment to ensure integrity and confidentiality.
The Company processes personal data in accordance with applicable privacy laws and regulatory requirements. Data collection is limited to what is necessary for AML/CFT, identity verification, and customer due diligence. Data shall be stored securely, access restricted to authorized personnel, and data transfers conducted under approved safeguards. Customers have rights to access, correct, or request deletion of personal data, subject to regulatory constraints and the Company’s legal obligations.
If suspicious activity or potential money laundering or terrorist financing is detected, the Company shall escalate the matter to the internal Compliance Officer and, where required, file a report with the competent financial intelligence unit and/or relevant public authorities in accordance with law. The Company cooperates fully with investigations and provides information within the legally prescribed timelines.
The Compliance Officer is responsible for the day‑to‑day enforcement of this policy. The Board provides oversight and approves material updates. All relevant staff receive regular AML/KYC training, including identification of red flags, reporting procedures, and data privacy requirements.
This policy is reviewed at least annually and whenever regulatory changes occur. Material amendments require board approval. Customers will be notified of changes in accordance with internal procedures and legal obligations.
Questions or requests related to KYC/AML policy may be directed to the Company’s Compliance Officer at the designated contact channel available to customers. All inquiries will be handled in accordance with applicable confidentiality and data protection requirements.
