99ab - Anti-money Laundering Policy

Purpose and Scope

99ab maintains an anti-money laundering (AML) and countering the financing of terrorism (CFT) program to prevent misuse of its platform for illicit purposes and to comply with applicable laws, licensing conditions, and industry standards. This policy applies to all customers, accounts, payments, and gaming activities conducted through 99ab and its affiliates, including onboarding, funding, wagering, and withdrawals.

It covers Know Your Customer (KYC), customer due diligence (CDD), ongoing monitoring, recordkeeping, and suspicious activity reporting.
Geographic controls apply; onboarding and activity may be restricted in jurisdictions where 99ab is not permitted to operate or where regulatory sanctions apply.
All products and services offered on the 99ab platform fall within the scope of this policy.

Governance and Oversight

The AML program is overseen by a designated AML Compliance Officer (the MLRO) who reports to senior management. The MLRO is responsible for implementing the program, supervising AML controls, coordinating with regulators as required, and ensuring timely reporting of suspicious activities. Regular risk assessments, policy reviews, and independent audits support ongoing effectiveness of controls across customer onboarding, payments, gaming activities, and data handling.

Know Your Customer and Identity Verification

On registration and at defined trigger points, 99ab collects information to verify identity and assess risk. Customers must provide truthful and complete data, including legal name, date of birth, residential address, contact details, and payment preferences. Acceptable documentation includes a government-issued identity document (e.g., passport or national ID) and a recent document confirming an address (e.g., utility bill or bank statement). A geolocation check confirms the customer is located in a permitted jurisdiction. Only one account per person, family, or shared environment is allowed. Login details must not be shared with third parties. If information is false or misleading, 99ab may suspend or terminate the account and refuse to provide services. Identity verification is completed within 1–3 business days under normal circumstances, with iterative verifications conducted as part of ongoing monitoring or upon material changes to personal data or payment methods. 99ab may request additional documentation to verify funding sources and ownership of funds when deposits or withdrawals exceed predefined thresholds or when activity warrants enhanced scrutiny.

Risk Classification and Enhanced Due Diligence

99ab employs a risk-based approach to AML. Customers are classified as Low Risk or High Risk. Low Risk customers undergo standard due diligence with ongoing monitoring. High Risk classification may be triggered by automated alerts or suspicious activity indicators, and requires enhanced due diligence (EDD). Triggers for EDD include large or unusual transaction patterns, rapid fund movements, complex ownership structures, high-risk jurisdictions, politically exposed persons (PEPs), and potential attempts to obfuscate ownership. EDD may require additional documentation, such as updated bank statements, evidence of source of funds, or interviews. If verification cannot be completed satisfactorily, 99ab may restrict activity, suspend withdrawals, or terminate the relationship.

Ongoing Monitoring and Recordkeeping

All customer accounts are subject to ongoing monitoring for irregular, suspicious, or potentially fraudulent activity. 99ab maintains comprehensive transaction histories, audit trails, and cross-references activity with related data sources. If indicators of money laundering or financing of terrorism are detected, the MLRO will investigate and escalate as appropriate. High-risk customers receive enhanced monitoring and more frequent reviews. Personal data, identification documents, verification results, transaction records, and communications are retained for a minimum of eight years after account closure or last activity, consistent with applicable law and regulatory requirements.

Prohibited Jurisdictions and Sanctions Screening

99ab prohibits onboarding and maintaining accounts for persons located in jurisdictions where operations are restricted or where sanctions apply. The company conducts ongoing sanctions and adverse-list screening at onboarding and throughout the customer relationship. If a customer is identified as residing in a restricted jurisdiction, services may be suspended or terminated, and information may be reported to the relevant authorities as required by law.

Suspicious Activity Reporting and Cooperation with Authorities

Any transaction or activity that appears irregular, suspicious, or inconsistent with a customer’s profile or risk controls must be escalated to the MLRO. The MLRO will assess and, where warranted, file a report with the applicable Financial Intelligence Unit (FIU) or regulatory authority promptly, typically within 24 hours of becoming aware of the matter. 99ab will cooperate with law enforcement and regulators, providing access to records and documentation necessary for investigations. Customers may be subject to account restrictions or termination during or after investigations.

Payments, Withdrawals and Verification Thresholds

Withdrawals are processed only after satisfactory verification of identity and funding sources. A withdrawal request must be submitted from the customer’s account. 99ab may withhold funds or request additional documentation if suspicious activity or incomplete verification is detected. A cumulative deposits or withdrawals threshold of 500 EUR or equivalent triggers enhanced verification requirements. Acceptable documentation includes: a valid passport or national ID, a recent utility bill or bank statement, and documentation corresponding to the selected payment method. 99ab may suspend withdrawals temporarily pending verification, investigation, or regulatory approval. Information provided by customers must be accurate; false or misleading information may result in account termination.

Data Protection, Privacy and Data Retention

99ab processes personal data solely for platform operation, AML compliance, and customer communications. Personal data is handled in accordance with applicable data protection laws. 99ab acts as data controller and employs appropriate security measures to protect data from unauthorized access or disclosure. Data may be shared with regulatory authorities, financial institutions, and service providers as necessary for AML and KYC purposes, subject to contractual protections. Personal data, including identification documents and verification results, is retained for eight years following account closure or last activity, unless a longer retention period is required by applicable law. Customers have rights to access, rectify, or delete personal data under applicable privacy laws.

Security, Training and Awareness

99ab maintains robust security controls to prevent unauthorized access to systems and data. Access is restricted to authorized personnel with least-privilege principles and strong authentication. Staff receive AML and security training on a regular basis, covering detection of money-laundering indicators, handling of sensitive information, and escalation procedures. Incident response procedures and comprehensive audit trails support ongoing transparency and accountability for AML activities.

Digital Assets and Cryptocurrency

If 99ab permits cryptocurrency deposits, the following controls apply. The first deposit may be conducted in cryptocurrency; subsequent deposits, wagers, and withdrawals must be in the same cryptocurrency. 99ab does not operate as a fiat currency exchange and does not convert cryptocurrency to fiat. Identity, age, and address verification must be completed before enabling cryptocurrency transactions, and crypto flows are subject to the same AML controls as other payment methods. Solvency proof and independent balance checks may be required to ensure funds are available for all bets and jackpots, with cryptocurrency holdings maintained in a manner that keeps funds traceable to the customer. The homepage will display the current exchange rate between cryptocurrency and fiat, and customers will be informed of the market-driven nature of cryptocurrency values. 99ab reserves the right to suspend or modify cryptocurrency activities to address compliance risks or regulatory changes.