AML Policy

The purpose of this AML Policy is to prevent the SwynoBet Platform from being used, knowingly or unknowingly, for money laundering, terrorist financing, sanctions evasion, or any other financial crime. The policy applies to every Player, every transaction, and every member of SwynoBet staff.

SwynoBet N.V. is licensed under License No. ALSI-202605013-FD1 and aligns its AML programme with the FATF Recommendations and applicable EU AML Directives, even where not strictly required by its licensing jurisdiction. We adapt our controls to evolving guidance from FATF, the EU, and major chain-analytics providers.

SwynoBet uses a risk-based approach. Each Player is scored on registration and re-scored continuously based on geography, deposit size, on-chain history, gameplay patterns, KYC outcome, and PEP/sanctions status. Controls escalate with risk: Standard Due Diligence (SDD) for low risk, full Customer Due Diligence (CDD) by default, and Enhanced Due Diligence (EDD) for elevated risk.

Every Player completes CDD before their first withdrawal. CDD includes:

• Verification of full legal name, date of birth, residential address, and nationality.
• Government-issued photo ID (passport, national ID card, or driving licence).
• Selfie / liveness capture matched against the ID document.
• Proof of address dated within the last three (3) months.
• Screening against global sanctions, PEP, and adverse-media lists.

EDD is triggered automatically for: high cumulative deposits, transactions involving privacy coins or mixers, exposure to sanctioned counterparties, jurisdictions on the FATF grey/black list, or any pattern flagged by our on-chain analytics provider.

On EDD, or where cumulative deposits exceed materiality thresholds, SwynoBet will request documented Source of Funds (SoF) and, in higher-risk cases, Source of Wealth (SoW). Acceptable evidence includes bank statements, payslips, employment contracts, sale-of-asset documentation, tax returns, or notarised attestations. Withdrawals are paused until satisfactory evidence is provided.

Every deposit and withdrawal is screened against:

• Sanctioned-address registries (OFAC, EU, UK HMT, UN).
• Known mixer, tumbler, and coin-join service addresses.
• Darknet-market, ransomware, scam, and stolen-funds clusters.
• Exposure scoring from established chain-analytics providers.

Deposits originating from blocked or high-exposure addresses may be quarantined, refunded to the originating address, or escalated to authorities depending on risk.

All Players are screened against PEP and sanctions databases at registration and re-screened on a rolling basis. Sanctioned individuals or entities are refused service. PEPs may be accepted only with senior-management approval and ongoing EDD.

SwynoBet's automated system raises red flags when patterns inconsistent with a Player's profile are detected. Examples include rapid deposit-withdraw cycles with minimal play, inconsistent geolocation, structuring below thresholds, or exposure to high-risk counterparties.

When the AML system raises a red flag on a withdrawal request, the request is paused and the Player receives the following notification: "Your account, KYC data, and balance need to be manually checked and reviewed by our AML team because the AML system has raised a red flag on your account. This will take 24–48 hours."

During the review, the requested withdrawal amount is returned to the Player's balance as SwynoCredits and the case is added to an internal queue. The AML team will either release the withdrawal, request further documentation, or in proven cases of abuse close the account and report under applicable law.

SwynoBet files Suspicious Activity Reports ("SAR") and Suspicious Transaction Reports ("STR") with the relevant financial-intelligence unit where required by law. Tipping-off the subject of a report is strictly prohibited.

All AML records — identification documents, screening results, transaction logs, and case notes — are retained for at least five (5) years after account closure, in encrypted form, with strict access controls. Retention may be extended where investigations are ongoing.

All SwynoBet staff complete AML/CTF training on hire and at least annually thereafter. Customer-facing and review staff receive additional role-specific training. Training records are retained and reviewed during internal audit.

SwynoBet has designated a Money-Laundering Reporting Officer ("MLRO") with responsibility for the AML programme, regulator liaison, SAR/STR filings, and internal escalation. The MLRO reports directly to senior management and operates with full independence.

SwynoBet does not accept Players resident in jurisdictions sanctioned by the UN, EU, US OFAC, or UK HMT, nor in any jurisdiction where online gambling is unlawful. The current restricted list is maintained inside the Terms & Conditions and may be updated without notice.

AML enquiries, regulator requests, and lawful disclosure orders should be sent to support@swynobet.com marked "AML / MLRO" in the subject line.