AML / KYC Policy

This policy applies to all Gamblix clients, partners and counterparties. It does not apply directly to the End Users of casinos operated by our clients — those players are subject to the operator's own AML/KYC programme, which we expect to comply with the standards set by the operator's licensing authority.

Before opening a commercial relationship we collect and verify: (a) the legal name, registration number and registered address of the client entity; (b) the nature of its business and target jurisdictions; (c) ultimate beneficial ownership above 25%; (d) directors and key management; (e) gaming licences held or applied for. We use independent registries, document verification and screening tools.

We apply enhanced measures where the client operates in a higher-risk jurisdiction, has a complex ownership structure, is a politically exposed person (PEP) or is connected to one, or where there is adverse media coverage. EDD may include source-of-funds checks, in-person meetings and senior-management approval.

We screen all clients, beneficial owners and key personnel against EU, UN, UK and OFAC sanctions lists at onboarding and on an ongoing basis. We do not enter into or maintain relationships with sanctioned parties.

We monitor commercial activity and update client records periodically (at least every 24 months for low risk, every 12 months for higher risk). Material changes — for example a change of ownership, a new licence or operations in a new jurisdiction — must be notified to us within 30 days.

All KYB documentation and transaction records are kept for at least 5 years after the end of the business relationship, in line with applicable laws. Records are stored securely and access is restricted to authorised personnel.

Suspicious activities are reported to the competent Financial Intelligence Unit (FIU) by our Money Laundering Reporting Officer (MLRO). Reports are confidential and tipping-off is strictly prohibited.

All Gamblix staff in client-facing, financial and compliance roles receive AML training at onboarding and annually thereafter. The MLRO reports directly to the board and provides regular updates on the effectiveness of the programme.