This document sets out the official Anti-Money Laundering and Counter-Terrorist Financing standards, together with the Know Your Customer framework, applicable to the services provided under the domain donyahotbet.com. By registering an account and using any service, users confirm they have read, understood, and accepted the entirety of this policy.
1) Scope and Statement of Compliance
a) This policy applies to all users, employees, contractors, payment partners, and affiliated service providers.
b) Controls are designed around a risk-based approach and aligned, where applicable, with international best practice, including FATF Recommendations, Directive (EU) 2015/849, and Regulation (EU) 2015/847 on information accompanying transfers of funds.
c) Users are solely responsible for complying with the laws of their country of residence. Where local law prohibits wagering or related activities, access to or use of services is not permitted.
2) Key Definitions
Money Laundering (ML): Any process designed to conceal or disguise the illicit origin of funds or assets.
KYC: Customer identification and verification procedures, including identity, address, and source of funds/wealth checks.
PEP: Politically Exposed Person, as well as close associates and family members, requiring enhanced due diligence.
RBA: Risk-Based Approach, tailoring controls to customer, channel, product, and geographic risk.
3) Governance, Responsibilities, and Independence
a) Ultimate responsibility for AML/KYC rests with senior management. An independent Anti-Money Laundering Compliance Officer (AMLCO) reports directly to senior management.
b) The AMLCO designs and implements controls, oversees monitoring, coordinates training, maintains records, and, where required by applicable law, files reports with competent authorities.
c) Decisions regarding temporary blocks, service discontinuation, suspicious activity escalation, and risk classification are within the AMLCO’s and management’s remit.
4) Transparency and Professional Conduct
a) Customer identification is mandatory prior to enabling financial features such as deposits, withdrawals, and currency exchanges.
b) Use of third-party bank cards or accounts, including rented or borrowed cards, is strictly prohibited.
c) Where possible, withdrawals up to the amount of the initial deposit are processed back to the original funding method.
d) Services may be suspended at any time if inconsistencies, suspected fraud, or sanctions/PEP hits are detected, pending completion of additional checks.
5) KYC Tiers and Thresholds
Identity verification is implemented in three progressive tiers. Access to higher limits and features requires successful completion of the corresponding tier. Enhanced Due Diligence (EDD) is applied to higher-risk profiles, PEPs, and sanctioned or embargoed geographies.
| Tier | Requirements | Access & Limits |
|---|---|---|
| Tier 1 |
Basic profile data: full name, date of birth, country of usual residence, gender, and full address. Email and phone verification; acceptance of Terms of Use and Privacy Policy. | Account access with limited functionality. Withdrawals require Tier 2 completion. Transactions are monitored automatically. |
| Tier 2 |
Upload a valid government-issued photo ID with four corners visible and sufficient clarity; a handwritten note showing six random digits placed next to the ID. Automated database checks to validate Tier-1 data. If automated checks fail, submit recent proof of address (≤ 3 months) such as a utility bill or a government certificate. | Activation of withdrawals and higher limits upon successful verification. Manual review by compliance staff may be requested. |
| Tier 3 |
Source of Funds/Wealth (SOF/SOW): employment letters and payslips, business ownership documents and financial statements, tax returns, asset sale contracts, inheritance documents, bank statements reflecting relevant inflows, or investment portfolio reports. PEP/sanctions screening and geographic risk assessment. | Access to high-value transactions. EDD may include video interview, additional documents, and senior-management approval. |
6) Customer and Geographic Risk Assessment
a) Countries are categorized as low, medium, or high risk. Lists are dynamic and updated to reflect international developments.
b) For medium-risk jurisdictions, thresholds may be lowered and additional verification applied. High-risk or sanctioned jurisdictions may be blocked.
c) Risk factors include PEP status, complex ownership structures, unusual transaction patterns, use of high-volatility assets, document inconsistencies, rapid currency or nationality changes, and device/IP anomalies.
7) Ongoing Monitoring and Lines of Control
a) First line: Acceptance of payments only through vetted providers with robust AML/KYC controls; pre-filtering of suspicious transactions.
b) Second line: Behavior-based and machine-learning monitoring overseen by the AMLCO; high-risk alerts escalated for human review.
c) Third line: Targeted manual investigations for high-risk cases, full SOW/SOF reviews, and decisions on account restriction or termination.
d) Red-flag indicators include repeated in-and-out flows without genuine activity, method mismatch between deposit and withdrawal, abrupt changes in behavior, multiple bank accounts, clustered devices/IPs, and attempts at structuring.
8) Financial Operations Rules
a) Where practicable, withdrawals up to the initial deposit amount must be returned to the original funding method. Any change of method requires compliance approval.
b) Payments may be temporarily held pending completion of enhanced checks.
c) Any transaction may be reported to competent authorities when legally required or when suspicion thresholds are met.
9) Acceptable Evidence for Address and Funds
- Address: recent utility bill (water, electricity, gas, internet) issued within 90 days, bank statement, or government residence certificate.
- Source of Funds/Wealth: payslips and employment letters; corporate documents and audited financials; tax filings; asset sale contracts with settlement proofs; inheritance documentation; broker/bank reports evidencing proceeds and corresponding credits.
- Documents must be legible, complete, and unaltered. Certified translations may be required where applicable.
10) Recordkeeping and Confidentiality
a) KYC files, transaction data, and related communications are retained for at least ten (10) years after the end of the business relationship or the relevant transaction, as permitted by applicable law.
b) Data are stored securely using encryption and strict access controls. Disclosures are limited to what is necessary and lawful.
c) Privacy-by-design is applied through data minimization, environment segregation, and audit-trail logging on a need-to-know basis.
11) Sanctions, PEP Screening, and Name Matching
Sanctions lists and watchlists are screened on an ongoing basis. Positive or potential matches may result in immediate service suspension while verification is completed. PEPs and their close associates are subject to EDD and, where appropriate, senior-management approval.
12) Change Management and Annual Review
a) Material changes to this policy require senior-management and AMLCO approval and are communicated by updating the online version.
b) An Enterprise-Wide Risk Assessment (EWRA) is conducted at least annually, with outcomes reflected in updated controls and procedures.
13) Training and Internal Audit
a) Mandatory AML/KYC training is provided to relevant staff at onboarding and annually thereafter.
b) Curriculum covers typologies, red flags, reporting procedures, data protection, and legal responsibilities.
c) Internal audit periodically evaluates control effectiveness and documents corrective actions for continuous improvement.
14) Actions on Suspicious Activity
- Temporary account or transaction blocks pending review.
- Requests for additional KYC/EDD documentation proportionate to risk.
- Relationship termination if unacceptable risk or confirmed breach is identified.
- Regulatory reporting in line with applicable laws and thresholds.
15) User Responsibilities and Safety Guidance
- Use only personal bank accounts/cards that match the registered account name.
- Do not segment transactions to evade thresholds or controls.
- Keep identity and contact information up to date and respond promptly to compliance requests.
- Protect login credentials and enable available security features; retain transaction confirmations for your records.
16) Complaints and Escalations
Users who wish to challenge a compliance decision should open a support ticket through their account, providing transaction IDs, dates, amounts, payment methods, and supporting documents. An initial response will be provided within operational timeframes, with complex cases escalated to the AMLCO.
17) Important Legal Notice
Gambling and betting activities are restricted or prohibited in certain jurisdictions. Access to or use of services in jurisdictions where such activities are illegal is not permitted. In case of conflict between this policy and mandatory local law, the latter prevails.
18) Contact
For AML/KYC inquiries, document submissions, or case updates, please use the secure in-account support channel. Do not transmit unnecessary sensitive data. Official communications will reference your case number where applicable.
Annex A: Illustrative Source-of-Funds/Wealth Checklist
- Employment: employer letter, last 3–6 months of payslips, matching bank credits.
- Business: corporate registry extracts, audited financial statements, tax returns.
- Assets: notarized sale contracts and settlement proofs for property/vehicle sales.
- Inheritance/Gifts: probate or legal documentation confirming receipt and amounts.
- Investments: broker/bank statements showing sales proceeds and account credits.
Versioning and Publication
This document may be updated to reflect regulatory changes, supervisory guidance, and evolving risk-management practices. The authoritative version is the latest edition published on donyahotbet.com.