Aml Policy

Scope and Purpose

This policy establishes Rkgg's mandatory anti-money laundering (AML) controls. It governs all customer onboarding, ongoing activity, and financial transactions across all Rkgg products. The objective is to detect, deter, and report money laundering and terrorist financing activities, while ensuring customer privacy and complying with applicable laws and licensing obligations.

Regulatory Framework and Licensing

Rkgg operates under the licensing regime applicable to its jurisdiction. The policy aligns with the requirements of the licensing authority and relevant financial crime laws, including customer due diligence, recordkeeping, reporting, and sanctions screening. Where lawful, the policy may be updated to reflect changes in regulation or licensing expectations.

Know Your Customer (KYC) and Identity Verification

  • Identity verification is required for all customers prior to processing withdrawals or when the risk assessment dictates. Verification may be performed through government-issued documentation.
  • Acceptable identity documents include a valid passport, national identity card, or a driver’s license. If no photo ID is available, a birth certificate may be considered, provided the applicant presents a clear copy and a live photo holding the certificate.
  • Documents must be legible, valid, and current. Expired documents are not accepted unless explicitly permitted by policy.
  • Verification requires the front and back of the document, with the card or passport number partially visible to verify the match with the registered account, while sensitive numbers are redacted as described in the document guidelines.

Proof of Address

  • Proof of residential address must be a utility bill or bank statement issued within the last three months and bearing the customer’s name and current address.
  • The document must be legible, with all four corners visible in the copy or scan.

Proof of Payment and Source of Funds

  • Verification of payment methods is performed to ensure funds originate from legitimate sources. Documentation requested is proportionate to the risk and payment type used for funding the account.
  • Card payments: provide copies of both sides of the card used for deposits with the cardholder’s signature and the first six and last four digits visible. The middle digits and the security code must be redacted. If a card cannot be shown, an alternative verification path may be requested.
  • e-wallets: provide a screenshot showing the registered email, account name, and masked account number to verify ownership.
  • Bank transfers: provide a bank statement dated within the last three months showing the bank name, account number, IBAN, and BIC; include a screenshot or PDF confirming a deposit to Rkgg.
  • Cryptocurrencies: provide a screenshot of the wallet showing the wallet address, transaction reference, and related account identifiers, where available.
  • Prepaid vouchers: schemes not tied to an ongoing banking or e-wallet relationship are subject to alternative verification paths as determined by risk assessment.

Document Submission Process

Customers shall submit required documents via the secure Documents area within the My Account section. Submissions must be clear, complete, and unaltered. Pending documents may delay processing of deposits or withdrawals.

Withdrawal Verification Timelines

  • If a withdrawal request is submitted, customers must supply the requested verification documents within 48 hours. Failure to provide documentation may suspend withdrawal processing.
  • Rkgg will review submitted documents within three (3) business days from receipt. Additional information may be requested if the initial submission does not meet verification standards.

Enhanced Due Diligence and Risk-Based Approach

Rkgg applies enhanced due diligence (EDD) for high-risk customers or activities, including high-value transactions, unusual patterns, or cross-border activity. In such cases, Rkgg may request additional information such as source of wealth, purpose of transactions, and references. Transactions exceeding a defined threshold or exhibiting risk indicators may trigger heightened monitoring and manual review.

Transaction Monitoring and Suspicious Activity Reporting

All customer activity is continuously monitored using automated screening and case-by-case review. Any suspicious activity, including structuring, unusual deposits, or attempts to circumvent verification, must be documented and reported to the appropriate regulatory authority in accordance with applicable laws and internal procedures. Rkgg will freeze or block funds as required during an investigation.

Sanctions, Politically Exposed Persons (PEP), and Adverse Jurisdiction Screening

Rkgg conducts ongoing sanctions, PEP, and adverse jurisdiction checks on customers and beneficial owners. Matches or high-risk associations are escalated to the compliance team for further action, which may include temporary account restriction, enhanced verification, or closure in accordance with legal obligations.

Data Privacy, Security, and Retention

Personal data gathered for AML purposes is processed in compliance with applicable data protection laws. Records created under this policy, including identity, address, and payment verification information, are retained for a minimum period of five (5) years after account closure or last interaction, or longer if required by law or licensing conditions. Access to AML data is restricted to authorized personnel and subject to audit checks.

Self-Exclusion and Responsible Gambling

Rkgg provides tools for self-exclusion and responsible gambling. Customers may request self-exclusion; during the exclusion period, account access is suspended and related activity is blocked. After the exclusion period, customers may apply for reactivation subject to compliance checks and a cooldown period if applicable. Linking AML actions to responsible gambling interventions ensures comprehensive risk management.

Recordkeeping, Training, and Audit

Rkgg maintains all AML records in secure repositories in accordance with regulatory requirements. All staff undergo AML training on an annual basis and upon changes to policy. Internal audits and regulatory examinations assess compliance with KYC, CDD, and monitoring controls.

Roles, Responsibilities, and Governance

The Compliance Team is responsible for implementing, enforcing, and updating this policy. Business units must cooperate with verification requests, provide required documentation, and ensure effective customer due diligence. Senior management approves material updates and ensures governance through periodic reviews.

Policy Review and Updates

This AML policy is reviewed at least annually or more frequently if required by changes in regulation, licensing, or risk profile. Updated versions become effective upon approval and notification to relevant stakeholders. Historical records of prior versions are retained in accordance with retention schedules.

Customer Rights and Contact Points

Customers may inquire about verification results, data processing, or the handling of AML concerns by contacting the designated compliance channel within Rkgg. Communications will be acknowledged and responded to in accordance with service level expectations and applicable law.