Anti-money Laundering

Introduction

666i is an online gaming operator licensed and supervised under applicable AML/CFT laws. This Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CFT Policy) governs all activities conducted through the 666i platform and applies to customers, personnel, contractors and affiliates acting on behalf of 666i.

Governing law and scope

The policy is based on guidance from international standard setters and local regulations relevant to online gaming. It is intended to prevent money laundering and the financing of terrorism and to ensure compliant conduct of customer onboarding, ongoing monitoring, and reporting obligations. It also addresses record-keeping and data protection requirements in force in the jurisdictions where 666i operates.

Governance and responsibilities

Ultimate responsibility for the AML policy lies with the 666i Director. The AML team implements procedures, maintains risk assessments, and reports to the Board. All staff receive training and are responsible for adhering to policy requirements and escalating suspicious activity in accordance with internal protocols.

Risk-based approach

666i applies a risk-based approach to identify, assess and mitigate ML/FT risks. The risk framework covers:

• Customer risk, determined by identity verification status, source of funds, and gaming activity profile;
• Product risk, associated with game types, payment methods and withdrawal channels;
• Interface risk, arising from non-face-to-face interactions and account access methods;
• Geographical risk, linked to customer residence, jurisdictional controls, and cross-border activity.

Risk levels drive the level of due diligence and monitoring. Risk assessments are conducted at onboarding and at monthly intervals thereafter.

Customer due diligence and verification

On onboarding, 666i identifies the customer prior to granting access to account features. Verification steps include:

• Documentary identity verification: a government-issued photo ID (passport, national ID, or equivalent).
• Proof of address: a recent utility bill, bank statement or government-issued document showing name and address.
• Age confirmation to comply with minimum age requirements.
• Determination of the purpose and intended nature of the gaming relationship.
• Sanctions and politically exposed status screened against applicable lists and internal risk criteria.

For corporate entities, beneficial ownership and control information is collected in accordance with policy requirements. The name on payment instruments must match the registered account holder; third-party payments are prohibited unless expressly approved and documented.

Enhanced due diligence

Additional verification applies where elevated ML/FT risk is identified, including:

• Politically Exposed Persons (PEPs) and immediate family members or close associates;
• Residence in or connections to high-risk or monitored jurisdictions;
• Discrepancies or suspicious indicators in the source of funds or wealth.

EDD requires supplementary documentation to corroborate wealth and source of funds and must be approved by senior management. Where appropriate, third-party verification or regulatory confirmation may be sought.

Ongoing monitoring and suspicious activity

666i monitors customer activity on an ongoing basis for signs of money laundering or terrorist financing. Examples of suspicious activity include, but are not limited to:

• Unusual deposit patterns or rapid movement between devices or payment methods;
• Use of multiple cards or wallets controlled by different emitters within short timeframes;
• Geolocation data that is inconsistent with declared residence or identity;
Reluctance to undergo verification or inability to confirm ownership of funds.

Any suspicious activity is escalated to the AML compliance team and may be referred to the competent supervisory authorities in accordance with applicable law and regulatory obligations.

Transaction monitoring and payment integrity

All deposits and withdrawals must preserve traceability to the customer account. Requirements include:

• The name on the payment instrument must match the 666i account holder; third-party payments are prohibited unless explicitly approved in writing and documented in the customer file.
• Payments from anonymous instruments are blocked; cryptocurrency transfers or anonymous wallets are not accepted unless a documented exception process is in place.
• Withdrawals are made to the original payment instrument or to another instrument that can be reliably linked to the customer; funds are not returned to third-party accounts.

Record-keeping and data protection

666i retains documents and data related to identification, verification, risk assessments and transactions in accordance with applicable AML regulations and data protection laws. Retention period is a minimum of five (5) years from the date of last activity or account termination, whichever occurs later, unless a longer period is required by law. Records are safeguarded with access controls and encryption where appropriate; processing complies with GDPR or equivalent data protection regimes applicable to the customer.

Training and governance

All staff receive AML/CFT training at onboarding and at regular intervals. Training covers detecting suspicious activity, verification procedures and escalation workflows. The AML team provides ongoing monitoring and reports to the Director and the Board. Internal controls are reviewed at least annually with timely updates to reflect legal changes and evolving risk.

Reporting and regulatory cooperation

666i reports suspicious transactions and activity to the competent authorities in accordance with regulatory requirements and cooperates with investigations as required. Where necessary, information and documentation are provided to authorities within legally mandated timeframes and in a secure manner. The Company maintains procedures to ensure timely and complete reporting and cooperation with law enforcement and supervisory bodies.

Amendments and review

This AML/CFT Policy may be amended at any time. Material changes are approved by the Board, and personnel are notified in writing. Compliance and awareness remain the responsibility of all staff both prior to and after changes.

Definitions

PEP means a person who is or has been entrusted with prominent public functions, and includes immediate family members and close associates as defined by applicable law. Customer refers to any natural person or legal entity with an account at 666i. Enhanced due diligence denotes heightened verification and monitoring for higher-risk relationships. Sanctions screening involves checking customers and counterparties against official sanctions lists. KYC means Know Your Customer; AML means Anti-Money Laundering; CFT means Counter-Terrorist Financing.