Anti-Money Laundering Policy

Block Dance S.R.L., operator of vegas7.ag, is committed to preventing the use of the Platform for money laundering, terrorist financing, sanctions evasion or any other financial crime. This Anti-Money Laundering (AML) Policy describes the controls we apply to meet that commitment and the obligations attached to gaming licence [LICENCE NO.] issued by [LICENSING AUTHORITY].

This Policy forms part of the Terms and Conditions and is read together with the KYC Policy and Privacy Policy.

Vegas7 has appointed a Money Laundering Reporting Officer (MLRO) responsible for implementing this Policy, overseeing monitoring, reviewing alerts, filing reports with the competent authority and maintaining records.

All staff with access to player data or transaction systems receive AML training on appointment and at least annually.

This Policy and the underlying risk assessment are reviewed at least annually and whenever there is a material change in the business, the regulatory environment or the threat landscape.

Each player is assigned a risk rating at onboarding and on an ongoing basis, taking into account jurisdiction, transaction volume and velocity, deposit and withdrawal patterns, wallet history, wagering behaviour and screening results.

Due diligence is scaled to the risk rating: standard due diligence for low-risk players, enhanced due diligence for higher-risk players as described in the KYC Policy.

Players from Restricted Territories are not permitted. Players from jurisdictions identified as higher risk by international bodies are subject to enhanced due diligence.

Identity, age and residency verification are performed in line with the KYC Policy before the first withdrawal and at the thresholds set out therein.

Screening is performed against sanctions lists, politically exposed person (PEP) lists and adverse media at onboarding and periodically thereafter. Matches are escalated to the MLRO for review before any further activity is permitted.

Enhanced due diligence, including source-of-funds and source-of-wealth evidence, is required for PEPs, high-risk jurisdictions, high-value players and wherever suspicion arises.

All deposit and withdrawal wallet addresses are screened using blockchain analytics tools for exposure to sanctioned entities, darknet markets, mixers, ransomware, stolen funds, scams and other high-risk sources.

Deposits from high-risk sources may be frozen pending investigation and may be returned to the originating address, retained in accordance with legal obligations, or reported to the competent authority.

Withdrawals are paid only to addresses controlled by the verified account holder. Withdrawals to third-party addresses, exchange deposit addresses flagged as high-risk, or addresses associated with other Vegas7 accounts are prohibited.

Deposits that do not confirm on the blockchain within a reasonable time, or that show signs of double-spend or deliberate delay, are treated as suspected fraud and handled in accordance with the Terms and Conditions.

Automated monitoring flags, among other things: deposits followed by withdrawals with minimal or no wagering; structuring of transactions to stay below verification thresholds; rapid movement of funds across multiple currencies or accounts; wagering patterns inconsistent with the player's profile; use of multiple wallets or devices; and activity linked to flagged blockchain addresses.

A minimum 1x wagering of each deposit is required before withdrawal. Withdrawals of funds that have not been wagered are declined until the requirement is met and may trigger enhanced review.

Flagged activity is reviewed by the compliance team. Accounts may be restricted, withdrawals held and additional documentation requested while a review is in progress. Players will not necessarily be informed of the reason for a review.

Where the MLRO has reasonable grounds to suspect money laundering, terrorist financing or other financial crime, a suspicious activity report is submitted to the competent authority in accordance with applicable law.

Vegas7 will not inform a player that a report has been or may be made (no tipping off). Funds may be frozen pending the outcome of any report or investigation.

Vegas7 cooperates fully with law enforcement, regulators and the licensing authority, including responding to lawful requests for information.

The following are prohibited and will result in account closure, forfeiture of funds and where appropriate reporting to the authorities: using the Platform to launder proceeds of crime; using third-party payment methods or wallets; operating accounts on behalf of others; structuring transactions to avoid verification; providing false information or forged documents; and any attempt to evade sanctions.

Records of customer identification, transactions, risk assessments, monitoring alerts, investigations and reports are retained for a minimum of five years from the end of the customer relationship or the date of the relevant transaction, whichever is later, or longer where required by law.

AML enquiries may be directed to the MLRO via [email protected].