This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy ("Policy") sets out the obligations, procedures, and standards applied by Innovex Tech Holdings Ltd. (registration number 15736), operator of kassabet at kassa-bet.org, to detect, prevent, and report money laundering, terrorist financing, and other financial crime. This Policy applies to all customers, transactions, and activities conducted through kassa-bet.org. All staff, agents, and third-party service providers acting on behalf of kassabet are required to comply with the principles contained herein.

1. Legal Basis and Regulatory Framework

kassabet is operated by Innovex Tech Holdings Ltd. under a licence issued by the Anjouan Gaming Board. As a licensed online gambling operator, kassabet is subject to the anti-money laundering and counter-terrorist financing requirements mandated by its regulatory authority. This Policy has been in effect since August 2024 and is reviewed and updated on a regular basis to reflect changes in applicable laws, regulatory guidance, and industry best practice.

The objectives of this Policy are to:

• Prevent kassa-bet.org from being used as a vehicle for money laundering or terrorist financing;
• Ensure that kassabet meets all obligations imposed by the Anjouan Gaming Board licence conditions;
• Establish clear, risk-based procedures for customer identification, verification, and ongoing monitoring;
• Protect the integrity of the platform, its customers, and the broader financial system.

2. Definitions

• Money Laundering (ML): The process by which criminally obtained funds are introduced into, moved through, or extracted from the legitimate financial system in order to disguise their illicit origin.
• Terrorist Financing (TF): The provision or collection of funds, by any means, with the intention or knowledge that they will be used to carry out terrorist acts.
• Know Your Customer (KYC): The process by which kassabet collects, verifies, and records information about customers to establish their identity and assess associated risk.
• Customer Due Diligence (CDD): Standard identity and verification checks applied to all customers.
• Enhanced Due Diligence (EDD): Additional, more rigorous checks applied to customers who present a higher risk profile.
• Politically Exposed Person (PEP): An individual who holds or has held a prominent public function, or a close associate or family member of such an individual.
• Suspicious Activity Report (SAR): A formal internal or external report raised where money laundering or terrorist financing is suspected.
• MLRO: The Money Laundering Reporting Officer, responsible for overseeing AML/KYC compliance at kassabet.

3. Risk-Based Approach

kassabet adopts a risk-based approach (RBA) to AML and KYC compliance. This means that the level of due diligence applied to any customer or transaction is proportionate to the risk that customer or transaction presents. Risk factors considered include, but are not limited to:

• The customer's country of residence and nationality;
• The payment methods used (including whether the customer transacts in fiat currency or cryptocurrency such as Bitcoin (BTC) or USDT);
• The volume, frequency, and value of deposits and withdrawals;
• Whether the customer is identified as a PEP or is subject to international sanctions;
• The source of funds declared and its plausibility relative to the customer's profile;
• Unusual patterns of play, including rapid cycling of funds through the account with minimal gaming activity;
• Requests to withdraw to a different method or currency than that used to deposit.

Higher-risk customers are subject to Enhanced Due Diligence and more frequent ongoing monitoring. Lower-risk customers may be subject to simplified or streamlined checks where permitted by applicable regulation, though a baseline level of identification and verification is required for all customers.

4. Know Your Customer (KYC) Procedures

4.1 When KYC Is Triggered

kassabet may request identity verification documents at any stage of the customer relationship, including but not limited to:

• Upon registration or first deposit;
• Before processing any withdrawal request;
• When a customer's cumulative deposits or withdrawals reach thresholds defined internally by kassabet's compliance function;
• When a customer requests access to higher withdrawal limits or VIP-tier benefits;
• When a transaction or pattern of behaviour triggers a risk alert or is flagged for review;
• At any point where the MLRO or compliance team deems verification necessary in the interests of regulatory compliance.

kassabet reserves the right to restrict deposits, withhold withdrawals, suspend account activity, or close an account pending satisfactory completion of KYC. Customers are encouraged to complete verification proactively in order to avoid delays in processing withdrawals, which ordinarily clear within 2 business days.

4.2 Standard Customer Due Diligence (CDD) — Identity Verification

All customers are required to provide the following as part of standard CDD:

• Proof of Identity (POI): A valid, unexpired government-issued document bearing the customer's full name, date of birth, and photograph. Acceptable documents include a national identity card, passport, or driving licence.
• Proof of Address (POA): A document confirming the customer's residential address, issued within the last three months. Acceptable documents include a utility bill, bank statement, or official government correspondence.
• Proof of Payment Method: Confirmation that the payment method used belongs to the customer. For card payments (Visa, Mastercard, Visa Electron, Maestro), this may include a photograph or screenshot of the card showing the last four digits and the cardholder name. For e-wallets such as Revolut or digital payment methods such as Apple Pay or Google Pay, a screenshot of the account or statement may be required. For cryptocurrency deposits (BTC, USDT), kassabet may request confirmation of wallet ownership or the originating wallet address.

4.3 Source of Funds (SOF) and Source of Wealth (SOW)

Where a customer's activity indicates elevated risk — whether through the size of deposits, the frequency of play, or other risk indicators — kassabet will request documentation to establish the source of funds used for gambling and, where appropriate, the customer's broader source of wealth. Acceptable documentation may include:

• Recent payslips or an employment contract;
• Tax returns or self-assessment documents;
• Bank statements covering a relevant period;
• Evidence of business income, investment returns, inheritance, or sale of assets;
• For cryptocurrency transactions, documentation evidencing the legitimate acquisition of the digital assets deposited.

kassabet notes that its platform supports deposits and withdrawals in fiat currency (EUR and equivalents) and cryptocurrency (BTC and USDT). Cryptocurrency and fiat accounts are maintained separately; a deposit made in BTC will be withdrawn in BTC. Customers transacting in cryptocurrency should be prepared to provide additional information regarding the origin of those funds where requested, given the inherent transparency and traceability considerations associated with digital assets.

4.4 Age Verification

kassabet does not permit gambling by persons under the age of 18. Age verification is conducted as part of the standard KYC process and may be triggered at any point. Where there is reasonable doubt about a customer's age, kassabet will restrict access to gambling services until satisfactory proof of age is provided. Any funds deposited by a person subsequently found to be underage will be returned and the account permanently closed.

4.5 Verification Process and Timelines

Customers will be notified via live chat, email, WhatsApp, or Telegram (kassabet's supported support channels, available 24/7) when documentation is required. Once documents are submitted, kassabet aims to complete verification within a reasonable timeframe. Customers should submit clear, legible, unedited copies of all requested documents. Altered, expired, or fraudulent documents will result in immediate account suspension and, where appropriate, a report to the relevant authorities.

5. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to customers who present a higher risk profile. EDD may be triggered by any of the following:

• Identification of the customer as a Politically Exposed Person (PEP) or a close associate or family member of a PEP;
• The customer's country of residence or nationality appearing on high-risk jurisdiction lists published by the Financial Action Task Force (FATF) or other recognised bodies;
• Significant or unexplained changes in account activity;
• Deposits or withdrawals approaching or exceeding the weekly cap of €4,000 or the monthly cap of €10,000 (noting that progressive jackpot wins are paid in full irrespective of standard caps, and that top-tier VIP members may be subject to individually negotiated limits — all such cases are subject to enhanced scrutiny);
• Use of cryptocurrency deposit or withdrawal methods at elevated values;
• Any internal or external alert or flag raised in connection with the customer.

EDD measures may include, without limitation: senior management approval for the continuation of the customer relationship; requests for detailed source of wealth information; increased frequency of ongoing monitoring; face-to-face or video verification; and the commissioning of independent third-party checks.

6. Politically Exposed Persons (PEPs) and Sanctions Screening

kassabet screens all customers against recognised PEP databases and international sanctions lists, including those maintained by the United Nations, the European Union, and other competent authorities, at the point of registration and on an ongoing basis. Customers identified as PEPs are automatically subject to EDD and require senior management approval before the business relationship may proceed or continue. Customers who appear on applicable sanctions lists will have their accounts immediately frozen and the matter reported to the relevant authorities. kassabet does not accept customers from sanctioned countries or territories.

7. Ongoing Monitoring

KYC is not a one-time process. kassabet conducts ongoing monitoring of all customer accounts throughout the customer relationship. Monitoring activity includes:

• Reviewing the consistency of transactions with the customer's declared profile and known gambling behaviour;
• Monitoring cumulative deposit and withdrawal activity against the platform's standard limits (minimum deposit €20; minimum withdrawal €40; daily withdrawal cap €1,000; weekly withdrawal cap €4,000; monthly withdrawal cap €10,000);
• Detecting unusual patterns such as rapid fund cycling, minimal play relative to total deposits, systematic structuring of deposits or withdrawals, or requests to withdraw using a method other than that used to deposit;
• Monitoring bonus usage — for example, unusually rapid completion of the ×40 wagering requirement attached to welcome bonuses, or exploitation of the Daily Cashback offer (which requires the customer's balance to be under €10 and total withdrawals not to exceed 60% of total deposits) — where such usage may indicate atypical behaviour;
• Periodic re-verification of customer information where documents have expired or circumstances have materially changed.

Where monitoring reveals activity inconsistent with a customer's profile or that raises suspicion of ML or TF, the account will be flagged for review and may be suspended pending investigation.

8. Suspicious Activity — Detection and Reporting

8.1 Red Flags

The following are examples of behaviour or circumstances that may indicate suspicious activity. This list is indicative and not exhaustive:

• Deposits made using multiple payment methods or from multiple sources without clear explanation;
• Requests to withdraw funds shortly after deposit, with little or no gambling activity in between;
• Deposits that consistently approach but do not exceed reporting thresholds (structuring);
• A customer who appears unconcerned about losing and focuses primarily on moving funds through the account;
• Provision of false, misleading, or inconsistent information during the KYC process;
• Refusal to provide requested documentation without reasonable explanation;
• Third-party funding — i.e., deposits received from a card, bank account, or wallet not belonging to the registered account holder;
• Unusual geographic access patterns — for example, logging in from multiple jurisdictions in a short period;
• Cryptocurrency activity at values that appear disproportionate to the customer's stated income or profile.

8.2 Internal Reporting

Any member of kassabet's staff, compliance function, or operational team who identifies or suspects ML or TF activity must report their concerns to the MLRO without delay. Internal reports must not be shared with the customer concerned (tipping-off). The MLRO will review each internal report and determine whether it is necessary to file a Suspicious Activity Report (SAR) with the relevant authority.

8.3 External Reporting

Where the MLRO determines that a SAR is warranted, it will be filed with the appropriate authority in accordance with the requirements of the Anjouan Gaming Board licence and any applicable laws. kassabet cooperates fully with law enforcement agencies and regulatory authorities in connection with any investigation into suspected ML or TF.

8.4 Tipping-Off Prohibition

kassabet strictly prohibits the disclosure to any customer, third party, or unauthorised person of the fact that a SAR has been filed, or that an ML or TF investigation is underway. Any breach of the tipping-off prohibition will be treated as a serious disciplinary and potentially criminal matter.

9. Record Keeping

kassabet retains all KYC documentation, transaction records, correspondence, and AML-related reports for a minimum of five (5) years from the end of the customer relationship or the date of the relevant transaction, whichever is later. Records are stored securely and in a format that allows their timely retrieval in response to requests from regulatory authorities or law enforcement. Retention and storage of personal data is carried out in accordance with kassabet's Privacy Policy and applicable data protection legislation.

10. Third-Party Deposits and Account Sharing

kassabet does not permit third-party funding. All deposits must be made using a payment method registered in the account holder's own name. As noted above, withdrawals are returned exclusively to the deposit method — a Bitcoin deposit is withdrawn in Bitcoin; a Visa deposit is withdrawn to the same Visa card. This policy eliminates a key mechanism by which third-party funds can be introduced or extracted. Any evidence of third-party funding will result in immediate account suspension, withholding of funds pending investigation, and, where appropriate, a SAR filing. Similarly, account sharing — the use of a registered account by any person other than the registered account holder — is strictly prohibited.

11. Cryptocurrency Transactions

kassabet accepts deposits and processes withdrawals in Bitcoin (BTC) and USDT, subject to a minimum equivalent of €20 for deposits and €40 for withdrawals. Cryptocurrency transactions carry specific ML and TF risks, including potential anonymity and the ease of cross-border transfers. Accordingly, kassabet applies the following additional measures to cryptocurrency accounts:

• Wallet ownership verification may be required, including confirmation that the originating wallet address belongs to the customer;
• Blockchain analytics tools may be used to assess the risk profile of incoming transactions, including screening for exposure to known illicit addresses or services;
• Source of funds documentation is more likely to be requested at lower thresholds for cryptocurrency accounts than for fiat accounts;
• Cryptocurrency accounts and fiat accounts are maintained separately; customers may not convert between them through the platform.

12. Responsible Gambling and AML Interaction

kassabet recognises that problem gambling and financial crime may, in some instances, be connected — for example, where a customer funds gambling from the proceeds of crime, or where gambling losses motivate financial dishonesty. As part of its commitment to player protection, kassabet operates responsible gambling tools that are also relevant to its AML obligations. Customers experiencing gambling-related harm are encouraged to use self-exclusion, deposit limits, and other responsible gambling mechanisms available on kassa-bet.org. Where kassabet identifies behaviour that may indicate both problem gambling and financial crime, both the responsible gambling and compliance functions will be engaged.

13. Staff Training

All relevant staff at kassabet receive training on AML and KYC obligations commensurate with their role and level of exposure to financial crime risk. Training covers the recognition of ML and TF red flags, the correct internal reporting procedure, the tipping-off prohibition, and the requirements of this Policy. Training is conducted at induction and refreshed on a regular basis, or whenever there is a material change to applicable law, regulation, or this Policy.

14. The Money Laundering Reporting Officer (MLRO)

kassabet has appointed a designated Money Laundering Reporting Officer (MLRO) who is responsible for:

• Overseeing the implementation and ongoing effectiveness of this Policy;
• Receiving and assessing internal suspicious activity reports from staff;
• Making SAR filings to the relevant external authority where required;
• Liaising with the Anjouan Gaming Board and other regulatory or law enforcement bodies in connection with AML and KYC matters;
• Ensuring that AML and KYC training is delivered and recorded;
• Reviewing and updating this Policy on a regular basis.

Customers wishing to raise AML or KYC-related queries may contact kassabet's compliance team via the 24/7 support channels: live chat on kassa-bet.org, email, WhatsApp, or Telegram.

15. Consequences of Non-Compliance

Failure by a customer to cooperate with kassabet's KYC and AML procedures will result in one or more of the following actions:

• Restriction or suspension of deposit and withdrawal functionality;
• Suspension of account access pending completion of verification;
• Withholding of pending withdrawals until satisfactory documentation is received;
• Permanent closure of the account;
• Forfeiture of bonus funds (including welcome bonuses, free spins, cashback, and rakeback) where their award or wagering is linked to an account found to be in breach of this Policy;
• Reporting of the customer and relevant transaction information to the appropriate regulatory or law enforcement authority.

kassabet reserves the right to take any or all of the above steps at its sole discretion, without prior notice, where the circumstances so require.

16. Policy Review

This AML / KYC Policy is reviewed at least annually, or more frequently where required by changes in applicable law, regulatory guidance, or the risk environment in which kassabet operates. The current version of this Policy is published on kassa-bet.org and supersedes all previous versions. The policy has been in effect since August 2024.

17. Summary of Key Thresholds