Kyc Policies

Purpose and Scope

Medinabet implements Know Your Customer (KYC) and Anti-Money Laundering (AML) controls to prevent financial crime within online gambling. This policy governs identity verification, ongoing monitoring of transactions, and the handling of suspicious activity for all customers, agents, and employees involved in Medinabet services.

Regulatory and Risk‑Based Framework

Medinabet operates in alignment with applicable financial crime laws and gambling regulations. A risk‑based approach determines the level of due diligence required for each customer and transaction, with enhanced scrutiny for higher‑risk profiles and activities.

Customer Identification and Verification (KYC)

Medinabet applies tiered due diligence: Simplified Due Diligence (SDD) for extremely low‑risk activity; Standard Customer Due Diligence (CDD) for typical customer profiles; and Enhanced Due Diligence (EDD) for high‑risk customers or transactions. Verification triggers and required documents are outlined below.

• Simplified Due Diligence (SDD): Applied only in clearly limited circumstances where the risk of ML/CTF is exceptionally low. Identity verification and ongoing monitoring remain, and Medinabet reserves the right to escalate to CDD or EDD if risk indicators emerge.
• Customer Due Diligence (CDD): Identity verification with government‑issued photo ID; name must match the account holder; address verification with a document in the account holder’s name; documents must be current and valid. Ongoing monitoring applies on a risk‑sensitive basis.
• Enhanced Due Diligence (EDD): Applied to high‑risk customers or transactions, including large or complex activity, customers from high‑risk jurisdictions, or identified PEPs. Additional documentation may include source of funds, source of wealth, recent pay slips or corporate records, and third‑party verification where required.

Identity and Source of Funds

As part of KYC, Medinabet requires:

• Proof of identity: Government‑issued photo ID (front and back where applicable) with full legal name that matches the account; the document must be valid and not expired within the next three months.
• Proof of address: A recent bank statement or utility bill in the account holder’s name and address, dated within the last three months and matching the identity name.
• Source of funds: For higher‑risk or larger transactions, documentation demonstrating the origin of funds may be requested.

Thresholds and KYC Triggers

Triggers to initiate or escalate KYC include: aggregate lifetime deposits totaling EUR 5,000 or more; a withdrawal request from an account that has not completed standard verification; or activity deemed suspicious by the risk monitoring framework. When triggered, the account proceeds through the standard KYC process before funds are released.

Ongoing Monitoring and Recordkeeping

Medinabet conducts ongoing monitoring of deposits, wagering, and transfers on a risk‑based basis. A transactional audit trail is maintained to support investigations and regulatory inquiries. Records are retained for a minimum of five (5) years after the end of the business relationship or after the completion of a transaction, in accordance with applicable laws and internal policy.

Suspicious Activity Reporting and Confidentiality

All personnel must report grounds for knowledge or suspicion of money laundering or terrorist financing to the designated Money Laundering Reporting Officer (MLRO). Suspicious Activity Reports (SARs) are confidential and must not be disclosed to the customer or any other party not involved in the investigation. Tipping off is strictly prohibited and may attract criminal penalties. The MLRO reviews disclosures and, where appropriate, files SARs with the competent authority in a timely manner.

Withdrawal and Deposit Procedures

Before processing a withdrawal, Medinabet reviews the customer’s deposit history and wagering activity to ensure consistency with the profile. Funds are returned to the original payment method where feasible. If documents are outstanding, withdrawals may be paused or rejected until verification is completed, and customers will be notified of any action taken.

Roles and Responsibilities

Senior management bears ultimate responsibility for the implementation of this policy. A designated MLRO operates with independence, receives disclosures from staff, and has authority to escalate and report to the relevant authorities. The MLRO is supported with adequate resources and direct access to senior management.

Training

All staff receive ongoing training on customer due diligence obligations, escalation procedures for suspicious activity, and data protection requirements. Training emphasizes the legal consequences of non‑compliance and the importance of maintaining confidentiality.

High‑Risk Jurisdictions

Customers resident in or transacting from jurisdictions identified as high risk by FATF or other regulators are subject to Enhanced Due Diligence and additional ongoing monitoring. Medinabet may impose restrictions, enhanced verification steps, or a temporary halt on gaming access where warranted by risk assessment.

Record Keeping and Data Security

Medinabet maintains a complete, auditable record of all compliance activities, including identity documents, risk assessments, SARs, escalation notes, and communications with law enforcement. Records are stored securely with access controls and encryption where appropriate, and kept for not less than five (5) years after the end of the customer relationship.

Offences and Compliance

Employees are subject to penalties under applicable anti‑money laundering and counter‑terrorism financing laws for failure to report suspicious activity, improper disclosure of SARs, or facilitating transactions designed to evade reporting obligations. Medinabet reserves the right to suspend or terminate accounts that breach this policy.

Vetting and Employment Checks

When recruiting, Medinabet conducts vetting procedures to confirm identity and suitability. This includes verification of identity, background checks, and at least two independent references. Applicants must be of legal age and not disqualified from employment related to gaming services.

Policy Governance and Amendments

This policy is reviewed at least annually by Medinabet’s Compliance and Risk Committee, with the MLRO and Compliance Officer as active participants. Amendments reflect changes in law, regulation, or internal risk assessments. The effective date of the current version is noted at the top of the policy.