Introduction
Qqwin implements a Know Your Customer policy to comply with applicable anti money laundering and countering the financing of terrorism laws and to prevent illicit use of the platform. This policy applies to all registered users and governs the collection, verification and ongoing monitoring of identity and financial information in connection with gaming activities and related transactions.
Purposes
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Prevent violations of this platform’s terms and applicable AML/CFT laws and regulations.
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Mitigate risks of money laundering, terrorist financing and other illicit activity.
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Prevent access by underage users and restrict use by individuals not authorized to gamble where prohibited.
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Detect cheating, collusion or other unlawful conduct in relation to gameplay and financial transactions.
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Safeguard the integrity of the platform and the financial interests of the company and its users.
Risk-Based Assessment
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Country risk: The user’s residence or domicile is evaluated against recognized high risk indicators, including third country status with strategic deficiencies as identified by competent authorities and listed high risk jurisdictions by recognized bodies, together with assessments of the jurisdiction’s AML/CFT framework and corruption risk.
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Customer risk: The user is reviewed for indicators such as political exposure, sanctions status, or patterns suggesting suspicious behavior, including excessive deposits, multi device or multi account access, or anomalous IP and geolocation data.
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Transaction risk: Spending patterns are reviewed to identify disproportionate or unusual activity relative to the user profile and declared source of funds.
Verification and Standard Verification
Standard Verification is triggered automatically when one or more criteria are met, including total cumulative transactions through the platform reaching or exceeding a threshold of 1000 USD or equivalent in other currencies, or when the user presents significant risk indicators. Verification is also conducted when prudent to do so based on risk assessment outcomes or internal controls.
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Documents required for verification include a clear copy or photo of the user’s government issued identity document and a recent payment instrument showing the cardholder name matching the account holder; CVV may be concealed while the cardholder name remains visible; the user’s facial image must be provided as part of the verification.
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Address verification may be requested through a document such as a utility bill, bank statement, or other recognized proof of address, in accordance with local regulatory requirements.
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To complete verification, the user may also be asked to confirm an email address or provide other data necessary to confirm identity and eligibility to gamble.
Enhanced Verification for PEPs and High-Risk Jurisdictions
Users identified as Politically Exposed Persons or located in high risk jurisdictions, or where the company reasonably suspects elevated risk, may undergo Enhanced Due Diligence. This may include additional source of wealth documentation, more detailed verification of ownership and control structures, or site specific checks. Final approval for enhanced verification rests with senior management. The company may request supplementary information in order to complete the verification process and maintain compliance with applicable laws.
Ongoing Activity Monitoring
All user activity is monitored for indicators of suspicious conduct. Suspicious activity includes, but is not limited to, irregular payment patterns, unusual device or geolocation changes, or reluctance to provide verification information. When suspicious activity is identified, the case is escalated to the antifraud department for risk assessment and further action as appropriate.
Transactions Monitoring and Controls
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All deposits and withdrawals must comply with verification requirements. The name on any payment card used for deposits or withdrawals must match the account holder’s name, and the electronic wallet address used for deposits or withdrawals must correspond to the user’s registered email.
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The platform does not accept payments from anonymous instruments and will not process withdrawals to third party payment instruments where ownership cannot be confirmed.
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Withdrawals from a verified account will be processed to the same payment instrument or to a bank account that reliably belongs to the user, subject to verification and applicable limits.
Record-Keeping and Data Protection
All documents and data obtained during verification, as well as related transaction records and supporting evidence, are stored and processed in accordance with applicable law, including data protection and privacy regulations. Retention periods comply with regulatory requirements and the platform’s Privacy Policy. Access to records is restricted to authorized personnel and to regulatory authorities as required by law.
Amendments and Communications
This policy may be updated by Qqwin at any time. Users will be notified of changes via their registered contact information. Continued use of the platform after notification constitutes acceptance of the updated policy.
Governance, Roles and Third-Party Obligations
The company maintains a designated Compliance Officer responsible for AML and KYC compliance. The policy requires service providers and partners to observe AML/KYC standards and provide information to regulators when required. The policy is reviewed and updated regularly to reflect changes in regulation and risk assessment practices.
