WinWin KYC & AML Policy

KYC and AML procedures are applied to each user profile to complete identity check and ID verification, prevent fraud, and support measures against money laundering and terrorism financing. These processes are part of the legal and regulatory framework that governs online gaming and betting services for users located in Bangladesh.

The KYC and AML framework aims to provide the following guarantees:

• Fair play and equal treatment of all registered users
• User safety and stronger account protection
• Transparency regarding how personal data and payments are handled
• Alignment with regulatory requirements in Bangladesh and internationally
• Security measures to reduce financial crime and misuse of the platform

Every new user must complete identity check and ID verification before gaining full access to gaming and betting functions. Additional document submission may also be required later, for example before large transactions, withdrawals, or in case of any suspicious activity on the account.

The platform may request one or more of the following document categories:

• Valid government-issued photo identification (passport, national ID card, driving licence, or similar document)
• Proof of residential address (such as utility bill, bank statement, municipal certificate, or similar document showing full name and address)
• Proof of ownership of payment instruments used for deposits or withdrawals (such as bank card confirmation, account statement, mobile financial service statement, or equivalent)
• Additional information to clarify the source of funds or source of wealth where required by AML rules

The platform applies AML controls and security measures to reduce the risk of money laundering, terrorist financing, fraud, and other illegal conduct. These controls are designed to identify suspicious activity, protect user safety, and support reporting obligations to competent authorities in Bangladesh or other relevant jurisdictions.

Key AML and transaction monitoring measures include:

• Continuous monitoring of deposits, withdrawals, and betting transactions to identify unusual patterns
• Automated detection rules to flag transactions that do not match the user profile or normal behaviour
• Enhanced due diligence for high-risk users, complex transactions, or higher-risk geographic locations
• Detailed review of large, frequent, or unusual transfers that may indicate money laundering or misuse of the service
• Risk scoring of user accounts, payment methods, and behaviours, updated on an ongoing basis
• Screening against international sanctions lists and identification of politically exposed persons (PEPs) where required by law
• Internal record-keeping and reporting to financial intelligence units or other authorities where AML or CTF rules impose such obligations

The platform imposes restrictions on certain activities to protect the integrity of KYC, AML, and responsible gaming controls. Any attempt to bypass identity check, transaction monitoring, or account protection rules may result in enforcement action.

Prohibited activities include, but are not limited to:

• Opening or using multiple accounts by the same individual, including accounts in other persons’ names
• Submitting forged, altered, stolen, or otherwise invalid documents during document submission or verification
• Using the platform for any form of money laundering or to disguise the origin of funds
• Manipulating systems, tools, bonuses, or games to gain unfair advantage or distort fair play
• Sharing, selling, or otherwise transferring account access, login details, or control of the account to any third party
• Using bank cards, mobile financial services, or other payment instruments that do not belong to the registered account holder
• Providing false personal data or misrepresenting identity, residence, or source of funds

Failure to respect KYC and AML rules may lead to immediate measures to protect the platform, other users, and the wider financial system. Violations of this policy can also trigger obligations to inform competent authorities in line with applicable laws in Bangladesh and other relevant jurisdictions.

Possible enforcement actions include temporary or permanent account suspension, freezing or confiscation of funds linked to suspicious activity, cancellation of bets or winnings, reporting to competent authorities where applicable.

Each user is responsible for providing accurate, complete, and up-to-date personal data during registration and throughout the customer relationship. Users must complete all required ID verification steps, follow any instructions for document submission, and react promptly to requests for further information from the compliance team. Users should only use payment methods that are legally owned and controlled by the same account holder whose details appear on the profile. Any change in personal details, such as address or contact information, should be updated without delay to ensure that records remain correct. Users are encouraged to report suspected fraud, unauthorised access, or other suspicious activity related to their account, transactions, or gaming behaviour as soon as possible.

The platform maintains fair play standards and transparency in all transactions to protect user safety and confidence in the service. These commitments are closely linked to responsible gaming practices, AML compliance, and robust security measures for all personal data and payments.

Core principles of fair play and transparency include:

• Compliance with KYC, ID verification, and AML regulatory requirements applicable to online betting and gaming
• Confidential handling and protection of personal data, documents, and financial information
• Ongoing transaction monitoring and review of accounts for indications of suspicious activity or misuse
• Prevention of manipulation, collusion, or any behaviour that undermines fair play conditions
• Accessible user support to address questions about account protection, AML rules, and responsible gaming
• Shared responsibility between the platform and each user to maintain a lawful and safe environment
• Equal rules and conditions for all users, without preferential treatment in AML, KYC, or dispute handling