سياسة مكافحة غسل الأموال واعرف عميلك

IGAXMING N.V. ("IGAXMING") is committed to preventing money laundering, terrorist financing, sanctions evasion and other financial crime in connection with the licensing and operation of its iGaming software. This Policy applies to: (i) all IGAXMING staff, contractors and agents; (ii) all customers (licensees) who purchase, lease or otherwise acquire rights to the Software; and (iii) any payment counterparty interacting with IGAXMING.

This Policy is aligned with the recommendations of the Financial Action Task Force (FATF), EU AML directives (4AMLD/5AMLD/6AMLD), the Curaçao National Ordinance on the Reporting of Unusual Transactions, OFAC, UN and EU sanctions regimes.

Before establishing a business relationship with a licensee, IGAXMING applies risk-based CDD measures including:

• verifying the legal identity of the customer (corporate registration, articles of incorporation, certificate of good standing where applicable);
• identifying ultimate beneficial owners (UBOs) holding 25%+ of the customer;
• verifying the identity of authorised representatives via government-issued ID;
• screening the customer, UBOs and representatives against sanctions lists (OFAC SDN, EU consolidated list, UN, HMT) and politically-exposed-person (PEP) databases;
• assessing the customer's intended jurisdiction(s) of operation, gambling licence(s) held or planned, and overall risk profile.

Enhanced Due Diligence (EDD) is applied to higher-risk customers (e.g. operations in higher-risk jurisdictions, PEPs, customers using complex ownership structures, high-value transactions).

Licensees of the Software undertake to, in their own operations: (i) maintain a documented AML/CFT programme appropriate to their jurisdiction and licence; (ii) implement player KYC at registration and prior to material transactions; (iii) screen players against sanctions and PEP lists; (iv) monitor transactions for suspicious patterns; (v) file suspicious transaction reports with the competent Financial Intelligence Unit when required; (vi) retain records for the minimum period required by applicable law (typically 5 years).

The Software includes optional AI-driven fraud-detection and KYC integration hooks. Use of these features does not replace the licensee's primary regulatory obligations.

IGAXMING does not establish or maintain business relationships with persons or entities listed on, owned by, or controlled by listed persons under any applicable sanctions regime. Customers identified post-onboarding as sanctioned will have their licence immediately suspended and funds frozen pending review.

IGAXMING staff are trained to recognise and report unusual or suspicious activity to the Money Laundering Reporting Officer (MLRO). The MLRO determines whether to file a report with the competent Financial Intelligence Unit. "Tipping off" the subject of a report is strictly prohibited.

CDD records, transaction records and internal AML communications are retained for a minimum of five (5) years after the end of the business relationship or the date of the relevant transaction, whichever is later.

All IGAXMING staff receive AML/CFT training at onboarding and at least annually thereafter. The MLRO reports directly to senior management and is empowered to act independently in respect of suspicious-activity decisions.

MLRO contact: compliance@igaxming.com — IGAXMING N.V., Heelsumstraat 51, E-Commerce Park, Curaçao.