Purpose and Scope
The AML & KYC Policy establishes Mmk121's approach to preventing money laundering and the financing of terrorism in accordance with applicable AML/CFT laws and licensing conditions. It sets out the obligations of the Company, its customers, and its service providers in relation to customer due diligence, ongoing monitoring, reporting, record keeping, and governance. The policy applies to all customers, applicants and users of the Mmk121 platform and related services.
Definitions
- AML means anti‑money laundering, including measures to detect and prevent money laundering and related predicate offences.
- KYC means know your customer, the process of verifying customer identity and assessing risk.
- CIP means customer identification program, the set of steps to establish customer identity.
- CDD means customer due diligence, the standard verification and risk assessment performed on customers.
- EDD means enhanced due diligence, intensified verification and monitoring for higher‑risk customers.
- PEP means politically exposed person, a person who may require enhanced scrutiny due to public functions.
- FIAU means Financial Intelligence Analysis Unit, the competent supervisory authority in the licensing jurisdiction of this operation.
Regulatory Oversight
Mmk121 operates under the supervision of the competent regulatory authority in its licensing jurisdiction. The Company implements AML/CFT controls and submits required reports to the relevant authorities in accordance with applicable laws and regulations. The FIAU or its equivalent constitutes the supervisory body responsible for compliance monitoring and enforcement actions related to AML/CFT obligations.
Customer Identification and Verification
All customers must provide accurate, current information at registration and maintain accuracy thereafter. Verification requires the submission of valid identification documents and proof of address, as described below, prior to or during use of the services.
- Identification documents: Government-issued photo ID (for example, passport, national ID card, or driver’s license).
- Proof of address: Utility bill, bank statement, or official document dated within the last three months.
- Personal identification is required to be provided on an individual basis; shared or corporate accounts are not permitted for personal gambling use.
Registration and Verification Timeline
Upon registration, customers have 30 days to complete the verification process. Failure to verify within the period results in account restrictions, which may limit access to certain features or suspend activity until verification is completed. Verification outcomes will be communicated promptly, and customers may be asked for additional information if necessary.
Account Ownership and Access
Accounts are issued for individual use and must not be transferred or shared. Any attempt to transfer or share an account will be treated as a breach of the terms and conditions and will result in account lockout and withholding of funds where applicable, pending investigation and regulatory compliance.
Verification Outcomes and Restrictions
- Approved: The account is fully verified and standard service access is available.
- Temporarily Approved: The account is verified for basic use but is subject to restrictions. Deposits may be limited to a cumulative amount (for example, USD 500) and withdrawals remain unavailable until full verification is completed.
- Rejected: Verification failed or was withdrawn. Access to services may be denied or terminated, with options to appeal in accordance with the appeals procedures.
- More information needed: Additional documents or validation steps are required; status remains unchanged until responses are received.
Enhanced Due Diligence (EDD)
The Company may apply EDD to higher‑risk customers or activities. EDD may include additional identity verification, origin of funds checks, enhanced documentation, third‑party verification, or targeted monitoring. The Company reserves the right to suspend activities pending completion of EDD.
Ongoing Monitoring and Transaction Surveillance
The Company conducts ongoing monitoring of customer accounts and transactions to detect unusual or potentially suspicious activity. Indicators may include large or rapid transaction sequences, activity inconsistent with known profile, and transfers involving high‑risk jurisdictions or counterparties. The Company maintains automated monitoring of all transactions exceeding USD 10,000 within any 24‑hour window and conducts corresponding reviews. Suspicious activity triggers internal escalation and reporting to the competent authorities where required by law.
Reporting and Compliance
The Company adheres to all mandatory reporting requirements for suspicious activities and transactions. Reports are submitted to the appropriate regulatory authorities in a timely manner in accordance with legal and licensing obligations. The Compliance function maintains documentation supporting such reports and the rationale for escalation decisions.
Data Privacy, Retention, and Access
Mmk121 processes personal data in accordance with applicable data protection laws and regulatory requirements. Personal data is kept confidential, used solely for AML/KYC and account management purposes, and retained for the period required by law. Data subjects may exercise rights to access, correct, or request deletion of their personal information in accordance with applicable law. The data controller for the processing is Mmk121, with processing activities described in the privacy notice. Records related to identification, verification, and transactions are retained as required by law and licensing conditions.
Record Keeping
The Company maintains complete and auditable records of customer identification, verification results, and financial transactions for the time periods mandated by law and regulatory requirements. Records are stored securely and made available to regulatory authorities upon request.
Compliance Officer and Governance
Mmk121 designates a Compliance Officer responsible for implementing this Policy, overseeing AML/KYC controls, coordinating investigations, and reporting to senior management and the regulatory authorities as required. The Compliance Officer maintains governance procedures to ensure timely remediation of gaps identified in audits or regulator inquiries.
Third‑Party Obligations
All third‑party service providers engaged by Mmk121 must comply with AML/KYC requirements and report relevant information to Mmk121 in a timely manner as required by law and licensing conditions. Third‑party risk governance procedures apply to onboarding, monitoring, and termination of service providers.
Training and Awareness
Employees receive ongoing AML/KYC training appropriate to their role, focusing on the identification of suspicious activity, data handling, escalation protocols, and regulatory changes. Training is refreshed at regular intervals or when regulatory developments require updates.
Policy Review and Updates
This Policy is reviewed at least annually or more frequently in response to regulatory changes, licensing conditions, or significant business changes. Updates become effective on the date stated in the updated policy published to customers.
User Rights and Contact
Customers may request access to their personal data, request corrections, or exercise applicable data rights in accordance with data protection laws. For AML/KYC inquiries or to raise concerns, customers should contact the Mmk121 Compliance team through the channels provided in the privacy notice or support materials. Play responsibly.