Introduction
The Anti-Money Laundering Policy (the Policy) governs Mmk121’s framework to deter, detect, and report money laundering and terrorist financing in all activities conducted on or through Mmk121. Mmk121 will comply with applicable AML regulations, maintain records of customer due diligence and transactions, and cooperate fully with competent authorities as required by law.
Policy Statement and Objectives
Mmk121 prohibits use of its services for any form of money laundering, terrorist financing, or sanctions violations. The Company adopts a risk-based approach to AML, implementing proportionate controls, and maintaining an ongoing culture of compliance. The objectives are to prevent illicit use of the platform, detect suspicious activity promptly, ensure timely reporting to authorities, and preserve audit trails for regulatory scrutiny.
Governance and Compliance Roles
The Company designates a Money-Laundering Compliance Officer (MLCO) who reports directly to the Board. The MLCO coordinates the AML program, oversees training, and drives periodic independent reviews of this Policy. The MLCO is authorized to file suspicious activity reports to the appropriate Financial Intelligence Unit without requiring prior approval and to escalate findings to the Board as necessary.
Know-Your-Customer and Customer Due Diligence
Onboarding requires mandatory information to establish identity and assess risk. At minimum, the customer must provide full name, residential address, valid electronic contact details, date of birth, government-issued identification number, and relevant payment information. All information supplied must be true, complete, and verifiable. The Company reserves the right to close an account if verification reveals data that is false or misleading.
- Proof of identity and address: onboarding documents may include a passport or national identity document and supporting address evidence such as a recent utility bill or bank statement.
- Geographic eligibility and screening: customers must not be located in Prohibited Jurisdictions or Sanctioned Jurisdictions, and IP-based and other checks will be used to enforce restrictions.
- Payment-method screening: sources of funds and payment origins will be reviewed to identify elevated AML risk.
Ongoing Monitoring and Sanctions Screening
Mmk121 applies ongoing monitoring of customer activity and implements transaction monitoring designed to detect unusual or suspicious behavior. The policy combines automated screening with manual review to identify red flags, including large or rapid transfers, atypical patterns, or activity inconsistent with the customer’s risk profile. When red flags are identified, the Company may suspend withdrawals, request additional information, or impose temporary limitations on deposits or transfers pending further review.
Enhanced Due Diligence
Whenever a red flag is triggered, the customer’s account will be subject to enhanced due diligence (EDD). EDD may require the customer to provide, among other items,:
- Full legal name and citizenship;
- Permanent residential address;
- Government-issued identification document(s) and identification numbers;
- Source of funds and source of wealth; and
- Third-party verification of the above information where appropriate.
The Company may engage third-party verification services to confirm the information provided.
Blocking of Customers and Account Management
Mmk121 may block or suspend a customer’s access or activity for any of the following reasons: failure to provide requested identification information; provision of false or misleading documents; attempts to conceal true location; residence in Prohibited or Sanctioned Jurisdictions; involvement in activities that trigger AML concerns; or other risk-based considerations. The Company reserves the right to block or suspend accounts at its sole discretion and to void bets or winnings where permitted by the Terms of Service.
Payouts and Verification
Withdrawals are subject to verification procedures. Customers must complete identity verification before processing payouts, including submission of identity documents and proof of address. In high-risk cases, the withdrawal function may be suspended until adequate due diligence is completed.
Reporting and Cooperation with Authorities
If a customer is identified as being on a sanctions list or linked to money laundering, terrorist financing, or other criminal activity, Mmk121 will file reports to the competent authority as required by law and regulatory guidance. The Company will preserve all relevant information and cooperate with authorities during investigations. Records of customer due diligence, transactions, and AML-related reports are retained in accordance with applicable legal and regulatory requirements.
Training and Awareness
All employees and contractors involved in onboarding, risk assessment, or fund flows receive AML training on an ongoing basis. Training covers identification of red flags, KYC procedures, and statutory reporting obligations, with refresher sessions conducted at regular intervals.
Policy Review and Updates
This Policy is reviewed at least annually and updated promptly to reflect regulatory changes, new products or services, and evolving risk indicators. Material amendments require Board approval and subsequent dissemination to staff.
Data Retention and Privacy
Records created under this Policy (including customer due diligence, transaction data, and AML-related communications) are retained in accordance with applicable law and regulatory guidance. Mmk121 implements appropriate security controls to protect personal data and complies with applicable data protection obligations.