Anti-Money Laundering Policy | Gamwiz Inc.

This policy applies to customer onboarding, deposits, wagering, withdrawals, promotions, wallet activity, account reviews, investigations, and business relationships.

The policy is designed to protect players, maintain platform integrity, and support Gamwiz compliance obligations.

Senior management is responsible for maintaining an effective AML/CTF control framework.

Operational responsibility is assigned to the compliance function and authorized staff who review KYC information, transaction activity, risk alerts, withdrawal requests, suspicious behavior, and enhanced due diligence cases.

• Staff involved in customer review, payments, risk, support, and operations must escalate unusual or suspicious activity promptly.

• Compliance decisions may include requesting further information, restricting an account, holding withdrawals, rejecting transactions, closing an account, or reporting suspicious activity where required.

Gamwiz applies a risk-based approach to AML/CTF controls. Customer risk may be assessed using identity information, country of residence, IP and session data, payment behavior, source-of-funds indicators, transaction patterns, gameplay behavior, withdrawal activity, device or account-linking indicators, sanctions exposure, adverse information, and other internal risk signals.

Gamwiz may require customers to provide personal information and identity documentation before or during use of the platform.

KYC review is mandatory when a customer’s lifetime deposits exceed EUR 5,000, upon withdrawal request, or whenever suspicious activity, high-risk indicators, enhanced due diligence triggers, or legal obligations require review.

• Government-issued photo ID, passport, national identity card, or driver’s license.

• Selfie or liveness evidence.

• Proof of address, bank statement, or utility bill.

• Wallet ownership evidence, source-of-funds information, or source-of-wealth information.

Enhanced due diligence may be applied where Gamwiz identifies higher risk, including unusual transaction behavior, high deposit or withdrawal volume, inconsistent customer information, use of VPN/proxy services, access from higher-risk jurisdictions, suspected multi-accounting, bonus abuse, fraud indicators, source-of-funds concerns, PEP exposure, sanctions proximity, adverse media, or other compliance concerns.

Enhanced due diligence may include additional identity verification, source-of-funds or source-of-wealth documentation, wallet ownership checks, explanation of gaming or transaction behavior, review of supporting contracts or bank statements, and senior compliance approval before withdrawals or continued activity.

Gamwiz monitors deposits, withdrawals, gameplay, wallet balances, payment processor events, blockchain-related activity, and account behavior on a risk-sensitive basis.

Crypto deposits and withdrawals are subject to blockchain confirmation, internal review, payment processor controls, KYC requirements, source-of-funds review where appropriate, and manual compliance review where risk triggers are present.

• Rapid deposit-withdrawal cycles.

• Minimal gameplay between deposit and withdrawal.

• Structuring or unusual velocity.

• Linked accounts, chargeback or reversal risk, abuse of promotions, unusual wagering patterns, or activity inconsistent with a customer’s profile.

• Use of the platform by minors or persons below the legal gambling age.

• Use from prohibited, restricted, or sanctioned jurisdictions.

• Use of false, misleading, stolen, or third-party identity information.

• Use of payment methods or wallets that the customer is not legally authorized to use.

• Money laundering, terrorist financing, fraud, sanctions evasion, or other illegal activity.

• Multi-accounting, collusion, automated betting, botting, bonus abuse, or manipulation of games, markets, promotions, or systems.

Where suspicious activity is identified, Gamwiz may investigate internally, request additional information, restrict account activity, delay or refuse withdrawals, close accounts, retain records, and file reports with competent authorities where required.

Gamwiz will not disclose suspicious activity reporting decisions to customers where doing so would be inappropriate or unlawful.

Gamwiz retains KYC records, transaction records, account notes, payment records, compliance decisions, and supporting documentation for a period consistent with applicable legal, regulatory, operational, and dispute-resolution requirements.

Records are maintained in a manner intended to support audits, regulatory inquiries, investigations, and law-enforcement requests where lawful.

This policy is reviewed periodically and may be updated to reflect changes in law, regulation, licensing requirements, platform operations, payment methods, risk profile, or internal controls.

Gamwiz Inc., Unit 207, Heritage Plaza II, Main Street, Charlestown, Nevis — Reg. C62780 — Licensed by the Anjouan Gaming Authority under license number ALSI-202602039-FI2.

Contact support@gamwiz.com for AML, account review, or compliance assistance.