Aml Policies

Introduction

Licwin maintains this AML policy to comply with anti money laundering and countering the financing of terrorism obligations. The policy sets out governance, controls and procedures to detect, prevent and report potentially illicit activity. It applies to all Licwin products and services and to all customers, agents and third party service providers acting on Licwin's behalf.

Scope and Application

This policy covers onboarding, ongoing activity and all cross border transactions conducted through Licwin platforms. It governs data collection, verification, screening, ongoing monitoring and reporting requirements. Licwin may suspend or terminate accounts where AML controls indicate risk or where prohibited activity is detected or suspected.

Definitions

• AML and CFT means measures to detect and prevent money laundering and the financing of terrorism.
• KYC means Know Your Customer procedures for identity verification and risk assessment.
• CDD means Customer Due Diligence, the standard level of verification for routine customers.
• EDD means Enhanced Due Diligence, heightened checks for higher risk relationships or transactions.
• PEP means Politically Exposed Person, a person who may require enhanced scrutiny due to public office or significant influence.
• Sanctions screening refers to screening against applicable government and international sanctions lists.
• Ongoing monitoring covers continuous review of activity to identify suspicious or unusual behaviour.
• Data subject rights are the rights of individuals under applicable data protection laws.

KYC and Identity Verification

On onboarding, Licwin requires verification of identity, age and residence. Verification will be completed within 24–72 hours after submission of required documents. If documentation is incomplete, Licwin will request missing information and may restrict access until verification is completed. Licwin may engage third party verification providers and perform checks against public and private sources to confirm identity.

1. Identity verification: submission of a government issued photo ID or national ID and live verification where required.
2. Address verification: recent document showing name and residential address (issued within the last 3 months).
3. Age confirmation: confirmation that the customer meets the legal minimum age for participation.
4. Supplementary verification: selfie or video check to corroborate identity as needed.

Customer Due Diligence and Enhanced Due Diligence

Licwin applies standard CDD for all customers and escalates to EDD for higher risk profiles, PEPs, large transactions or complex ownership structures. Risk is assessed at onboarding and during ongoing activity. EDD may include source of funds and source of wealth verification, additional documentation and enhanced ongoing monitoring.

• Low/Standard risk: routine identity checks and ongoing review at defined intervals.
• Medium risk: periodic review with additional data checks.
• High risk: intensive verification, continuous monitoring and documented escalation procedures.
• Thresholds for EDD example: any single transaction or cumulative activity above EUR 10,000 triggers enhanced review; ongoing high risk indicators trigger additional scrutiny.

Sanctions, PEP and Adverse Media Screening

Licwin conducts ongoing sanctions, PEP and adverse media screening on all customers as part of AML control measures. Any positive match or risk indicator triggers immediate escalation, temporary restrictions on activity and a formal review by the AML compliance function. If required by law, Licwin reports findings to the appropriate authorities and acts in accordance with regulatory obligations.

Ongoing Monitoring and Case Management

Licwin continuously monitors customer activity to identify unusual or suspicious patterns. Detected alerts are reviewed by the AML compliance team, documented in case files and escalated for further action as appropriate. High risk cases may result in enhanced monitoring, additional verification and, where necessary, account limitations or closure.

• Transaction monitoring: automated and manual review of deposits, withdrawals, bets and transfers.
• Case management: maintain a complete file for each notable activity, including actions taken and rationale.
• Suspicious activity reporting: where required by law, submit timely reports to the competent authorities.

Data Collection, Processing and Purpose

Licwin collects personal data to perform AML checks, verify identity, assess risk and comply with legal obligations. Data categories include identification data, contact details, financial information, transactional data, device and usage data, and communications content as necessary for investigative and compliance purposes. Data may be collected directly from the customer, automatically through the Licwin platforms and via trusted third party sources. Data minimization principles apply and data is processed only for purposes related to AML/CFT compliance, licensing obligations and related regulatory requirements.

Data Retention and Records

Licwin retains records for the period required by applicable law and regulatory obligations, and for a period sufficient to manage risk, investigate disputes and defend legal rights. In practice, records related to identity, verification, transactions and compliance activity are retained for a minimum period after account closure consistent with regulatory guidelines and then securely archived or purged as required by law.

Information Sharing and International Transfers

Licwin may share information with regulators, financial institutions, payment processors, and AML service providers as necessary to fulfil legal obligations. Where data is transferred across borders, Licwin applies appropriate safeguards and ensures processing is subject to legally enforceable data protection requirements in accordance with governing law.

Data Security and Confidentiality

Licwin implements reasonable technical and organizational measures to protect personal data, including access controls, encryption of data in transit and at rest, incident response procedures and regular security testing. Access to data is restricted to staff with a legitimate need to know, subject to confidentiality obligations. We maintain separate safeguards for sensitive information and do not disclose data beyond what is necessary for AML purposes.

Rights of Data Subjects

Data subjects may exercise rights under applicable law, including access to personal data, correction of inaccurate data, deletion where lawful and feasible, restriction of processing, data portability and objection to processing for direct marketing or other purposes. Requests should be submitted to Licwin compliance and will be addressed within the timelines required by law, and not exceeding 30 days unless extended for complex processing.

Direct Marketing and Communications

Licwin may process personal data for direct marketing of its own products and services where there is a lawful basis such as consent or legitimate interest. Customers may opt out at any time via the preferences centre or by contacting compliance. Marketing communications may be recorded where permitted by law and shall respect the customer’s opt out choices.

Self Exclusion and Responsible Gambling

Licwin supports self exclusion and responsible gambling measures. Customers may request self exclusion, limit setting or temporary blocking of accounts. Data generated through RG controls is used to manage risk and protect customers. Exclusion measures may be reviewed or lifted only in accordance with Licwin policy and regulatory requirements.

Governance, Training and Compliance

Licwin maintains an AML compliance program led by a designated compliance officer. The program includes regular risk assessments, policy reviews, internal controls, audits and board reporting. All staff receive AML/CFT training and testing, with additional training for high risk roles and scenarios.

Reporting and Cooperation with Regulators

Licwin cooperates with regulatory authorities and law enforcement in all AML/CFT matters. We maintain procedures for timely reporting of suspicious transactions and for regulatory inquiries, and we preserve records to support any investigations or audits conducted by competent authorities.

Contact and Availability

For questions about this policy or to submit compliance requests, customers may contact Licwin compliance at [email protected] or reach the support team through official channels.