Purpose and Scope

Betway's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) policy establishes the controls Betway implements to prevent, detect, and report money laundering and terrorist financing. The policy applies to all Betway products and services offered to customers, including online casino, live casino, sportsbook, and ancillary services, across regulated markets where Betway operates.

Regulatory Framework and Risk-Based Approach

Betway complies with applicable laws and regulatory requirements in each jurisdiction in which Betway operates. The policy adopts a risk-based approach to AML/CTF, including an annual risk assessment of products, customers, and geographies; maintenance of risk profiles; and implementation of proportionate controls based on risk level. Senior management bears ultimate responsibility for the effectiveness of the AML program, with an independent Money Laundering Reporting Officer (MLRO) empowered to act objectively and independently.

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

Betway applies CDD for all customers and transactions. In higher‑risk scenarios, Betway applies Enhanced Due Diligence (EDD). Betway distinguishes between:

• Default CDD – standard verification of identity and basic suitability checks consistent with the level of risk.
• Simplified CDD – applied only when risk is assessed as low and does not require extensive checks.
• Enhanced Due Diligence (EDD) – applied for high-risk customers, including additional documentation and ongoing monitoring.

Triggers for EDD include cross-border activity into or from high‑risk jurisdictions, politically exposed persons (PEPs), unusual or complex ownership structures, or evidence of funds with unclear provenance. Documentation requested under EDD may include source of funds, source of wealth, and validation of business or employment activities.

Identification and Verification (KYC)

Minimum data required for onboarding includes: full name, date of birth, residential address, nationality, and government-issued identity number or passport/ID. Betway may request documentation including an unexpired government-issued identity document and proof of address (e.g., utility bill, bank statement) not older than six months. Verification is completed prior to account activation where practicable and no later than 30 days from initial application. Betway may limit or suspend access to services pending verification.

Source of Funds and Source of Wealth

Customers must provide information or documentation sufficient to determine the source of funds for transactions and, where applicable, the source of wealth. In higher-risk cases Betway will obtain evidence of source of funds (e.g., bank statements, payslips) and source of wealth (e.g., recent tax filings, corporate records). Betway may require that initial funds be deposited from an account in the customer's name with banks subject to adequate CDD standards. Betway will not process funds from third-party sources where ownership cannot be established.

Ongoing Monitoring and Transaction Screening

Betway conducts ongoing monitoring of customer activity on a risk-based basis. This includes reviewing transaction patterns, deposit and withdrawal activity, and gaming behavior to detect anomalies inconsistent with the customer profile. Records of monitoring, including escalation decisions, are retained in accordance with the record retention policy. Transactions that trigger suspicion are subject to enhanced review and potential hold or reversal until verification is completed.

Suspicious Activity Reporting (SARs) and Escalation

All Betway staff must report grounds for knowledge or suspicion of money laundering or terrorist financing to the designated MLRO. Disclosures must be made confidentially and promptly; tipping off is strictly prohibited and may attract criminal penalties. The MLRO is responsible for reviewing disclosures, filing SARs with the appropriate authorities where required, and coordinating external reporting as permitted by law. Staff must not discuss ongoing investigations with customers or any third party.

Roles, Governance and Training

Senior Management holds ultimate accountability for the implementation and effectiveness of the AML program.

Money Laundering Reporting Officer (MLRO) has independent authority to act and responsibility to receive disclosures, supervise SARs, and liaise with regulators. The MLRO maintains resources adequate to perform duties and ensures timely escalation of any red flags.

Compliance and Risk Committee comprises the MLRO, the Compliance Officer, and other senior representatives. The committee reviews AML governance and risk at least quarterly.

Staff Training includes mandatory initial and ongoing training on CDD/EDD, SAR procedures, and identification of suspicious activity. Training emphasizes that failure to comply may carry criminal or regulatory consequences.

Record Keeping and Data Retention

Betway maintains comprehensive records sufficient to support investigations by competent authorities. Retention periods comply with applicable laws and regulatory requirements and shall be not less than five years from the end of the business relationship or the date of the last transaction, whichever is later. Records include customer identification documents, verification results, transaction records, and communications with the MLRO or regulators.

High-Risk Jurisdictions, PEPs and Sanctions

Betway applies enhanced due diligence for customers from or transacting with high‑risk jurisdictions identified by FATF and local regulators. Customer relationships involving PEPs or other politically exposed individuals require elevated scrutiny, ongoing monitoring, and appropriate approval thresholds. Betway screens against sanctions and restricted-party lists and will block or terminate relationships where prohibited by law.

Vetting and Internal Controls

Betway maintains internal controls to prevent misuse of systems for illicit purposes. New staff undergo vetting and background checks, with identity verification and reference checks prior to access to sensitive systems. The company maintains a dedicated MLRO and ensures independence of investigations and reporting.

Data Protection and Privacy

Betway processes personal data in accordance with applicable data protection laws and Betway's Privacy Policy. Data is stored securely, accessed only by authorized personnel, and transfers, where applicable, are governed by appropriate safeguards. Individuals have rights to access and rectify personal data held by Betway, subject to regulatory requirements and security considerations.

General Provisions and Compliance

Breaches of this policy may result in disciplinary action up to termination. Betway reserves the right to suspend or terminate accounts, deny access to services, or reverse transactions where AML/CTF controls have been compromised or where required by law.