Anti-Money Laundering (AML) Policy – Go2Win

1. Purpose and Commitment

Go2Win is committed to preventing its platform from being used for money laundering, terrorism financing, or any other financial crimes. This policy outlines our obligations, internal controls, and procedures to ensure full compliance with applicable AML/CTF regulations.

2. Legal Framework

• FATF (Financial Action Task Force) Recommendations
• EU 5th and 6th AML Directives
• Curacao Gaming Authority Compliance
• Local legislation in supported jurisdictions

3. Scope of Policy

This policy applies to:

• All Go2Win users and account holders
• All employees, agents, affiliates, and providers
• All products and services under Go2Win

4. Definitions

• Money laundering: hiding or disguising illegal funds
• Terrorist financing: using funds to support terrorism
• CDD: verifying customer identity
• EDD: enhanced verification for high-risk users

5. Risk-Based Approach

We prioritize AML efforts based on:

• Transaction size and frequency
• Country risk level
• Suspicious patterns (e.g. fast deposits/withdrawals)

6. Know Your Customer (KYC)

6.1 Account Verification:

• Name, Date of Birth, Address
• Government-issued ID
• Proof of address (issued within the last 3 months)
• Payment method proof (if needed)

6.2 Source of Funds:

Required for high deposits, suspicious activity, or VIP players.

7. Monitoring and Reporting

• Real-time transaction monitoring
• Suspicious Activity Reports (SARs) to internal AML Officer and Financial Intelligence Units (FIUs)

8. Recordkeeping

Documents and logs are retained for at least 5 years, including:

• KYC documentation
• Transaction history
• SARs and internal reviews

9. AML Officer & Staff Training

AML Officer:

• Oversees policy enforcement and reporting
• Coordinates training programs
• Interfaces with regulators

All staff receive mandatory AML training on a regular basis.

10. Prohibited Activities

• Anonymous or pseudonymous accounts
• Third-party payments
• Deposit structuring (smurfing)
• Fund movement without gameplay
• Use of shell companies or unverified crypto wallets

11. Sanctions & PEPs

All users are screened against international sanctions lists including OFAC, UN, and EU. Politically Exposed Persons (PEPs) are subject to Enhanced Due Diligence (EDD).

12. Enforcement

• Account suspension or closure
• Freezing of funds
• Legal action and/or regulatory reporting

13. Policy Review

This policy is reviewed annually or upon regulatory updates.
Last reviewed: July 2025

14. Contact

For AML-related queries, please contact: aml@go2win.io

Summary

Go2Win ensures AML integrity through checks, monitoring, and global compliance standards. We maintain zero tolerance for money laundering, terrorism financing, or abuse of our platform.