Aml & Kyc Policy

Introduction

Roobet is committed to preventing money laundering and the financing of terrorism across all gambling services. This AML and KYC Policy establishes the framework for customer due diligence, ongoing monitoring, data handling, and regulatory cooperation necessary to maintain the integrity of Roobet’s operations.

Scope and Applicability

This Policy applies to all Roobet customers, prospective customers, and any person who interacts with Roobet platforms for account creation, funding, gameplay, or withdrawals. It covers all products offered by Roobet, including casino and live gaming services, and governs onboarding, ongoing activity, and termination of accounts, regardless of jurisdiction, subject to applicable local laws and licensing requirements.

Definitions

  • Anti Money Laundering (AML): measures to detect, prevent and report money laundering activities.
  • Countering the Financing of Terrorism (CFT): actions to prevent funding of terrorist activities.
  • Know Your Customer (KYC): identification and verification of customer identity and risk profile.
  • Customer Due Diligence (CDD): steps taken to verify identity and assess risk.
  • Enhanced Due Diligence (EDD): intensified verification and monitoring for higher risk customers.
  • Politically Exposed Persons (PEP): individuals who hold prominent public positions or their family members or close associates.
  • Sanctions Screening: checking customers against applicable sanctions lists.
  • Source of Funds (SoF) and Source of Wealth (SoW): information detailing the origin of funds and overall wealth.

Legal and Regulatory Compliance

Roobet conducts its business in accordance with applicable AML and CFT laws, and any regulatory licensing requirements. Roobet reserves the right to suspend or terminate services where there is non compliance or where risk indicators arise from monitoring, screening, or corroborating information provided by the customer.

Governance and Roles

The Roobet Compliance Officer is responsible for implementing this Policy, ensuring appropriate risk assessments, and overseeing communications with regulators. The Board approves policy updates and resources necessary for effective implementation. All Roobet employees and contractors involved in customer onboarding, payment processing, or security operations must comply with this Policy and receive regular training.

Onboarding and Identity Verification

  1. Data collection: During account registration, Roobet collects identifying information including full name, date of birth, residential address, email, and contact numbers.
  2. Identity verification: Customers must provide government issued identification (passport, national ID card, or driving license) and a secondary document to verify identity when required.
  3. Age verification: All customers must be at least 18 years of age prior to account activation.
  4. Address verification: Proof of address no older than three months is required (for example, a utility bill or official document in the customer’s name).
  5. Risk-based SoF/SoW: For standard deposits, a basic source of funds check is performed; higher risk scenarios trigger enhanced documentation (see SoF section).
  6. Account activation: A customer is activated once identity, age, and address verification are satisfactorily completed and the customer has acknowledged the Terms and Conditions and this Policy.

Risk-Based Customer Due Diligence

Roobet applies a risk-based approach to CDD, classifying customers as low, standard, or high risk. The risk classification determines the scope and frequency of verification and monitoring procedures.

  • Low risk: Basic identity verification and routine monitoring applied.
  • Standard risk: Ongoing verification and periodic review of account activity; enhanced scrutiny for transactions or patterns that deviate from expected behavior.
  • High risk: Non-resident status in certain jurisdictions, PEPs, adverse media, complex ownership structures, or unusual activity trigger Enhanced Due Diligence and supervisory approval.

Source of Funds and Source of Wealth

Roobet requires reasonable evidence of SoF and SoW for deposits that exceed the following thresholds within a rolling 30 day period or for any single deposit that appears inconsistent with the customer’s profile:

  • Deposits up to the equivalent of 5,000 USD: documentation may include recent pay slips, employer statements, or personal bank statements showing the source of funds.
  • Deposits above the equivalent of 5,000 USD: Roobet requires additional documentation such as bank statements covering the last three months, the origin of funds documentation, or third-party verification where applicable.

Documentation may be provided through Roobet’s secure submission channel. Where funds originate from businesses or non-salary sources, additional corporate documentation may be required.

Ongoing Monitoring and Review

Roobet continuously monitors customer activity to identify suspicious or unusual patterns. Monitoring includes:

  • Transaction screening against risk indicators, including large or out-of-pattern deposits, rapid movements to and from high-risk jurisdictions, and structuring activity.
  • Automated risk scoring updated with each significant event or trigger.
  • Periodic review of KYC information, with re-verification triggered by changes in risk profile, product use, or regulatory requirements.

Enhanced Due Diligence

EDD applies where a customer is assessed as high risk or where indicated by ongoing monitoring. EDD measures include, but are not limited to:

  • Verification of source of funds and source of wealth with supporting documentation.
  • Independent corroboration of customer information where feasible.
  • Frequent updates to risk assessment and extended monitoring of transactions and counterparties.
  • Senior compliance approval for high risk onboarding and material changes to the business relationship.

Sanctions, PEP and Adverse Media Screening

Roobet screens customers against applicable sanctions lists, PEP lists, and negative media indicators. If a match or adverse indicators arise, Roobet will:

  • Place the account under enhanced monitoring;
  • Pause or limit further activity if necessary;
  • Notify the appropriate regulator and, where required, obtain legal counsel guidance prior to proceeding.

Record Keeping and Data Retention

Roobet retains records to comply with applicable laws and for regulatory investigations. Personal data, identity documents, transaction records, and risk assessments are retained for a minimum of eight (8) years after account termination or last activity, whichever is later, unless a longer period is legally required or consent for longer retention is obtained.

Privacy, Security and Data Protection

Roobet implements appropriate technical and organizational measures to protect personal data, including access controls, encryption in transit and at rest, and secure storage. Personal data is processed only for the purposes described in this Policy and in accordance with applicable data protection laws. Cross-border data transfers comply with safeguarding mechanisms appropriate to the transfer, including data minimization and retention controls.

Disclosure and Cooperation with Authorities

Roobet may disclose customer information to competent regulatory authorities, law enforcement agencies, or other third parties as required by law, regulation, court order, or legitimate regulatory investigation. Such disclosures are restricted to the minimum scope necessary to fulfill the legal obligation.

Employee Training and Awareness

Roobet provides ongoing AML and KYC training to all relevant personnel. Training covers identification of suspicious activity, regulatory requirements, and procedures for escalation and reporting.

Policy Maintenance and Review

This Policy is reviewed at least annually and whenever there are regulatory changes or material changes to Roobet’s services. Updates are approved by the Compliance Officer and communicated to the relevant personnel and customers as required by law.

Reporting and Escalation

Employees must promptly report suspicious activity through Roobet’s internal reporting channels. Roobet will investigate promptly, Escalate to appropriate authorities when required, and maintain records of all investigative steps and outcomes.

Contact Information

For questions about this Policy or to submit information requests or concerns, contact Roobet Compliance at [email protected].