Aml

Scope and Purpose

Bdok applies this Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy to all customer onboarding, account activities, and financial transactions conducted through Bdok services. The policy aims to prevent the use of Bdok for money laundering, terrorist financing, or other illicit conduct while ensuring compliance with applicable laws and regulatory expectations.

Risk Management and Classification

Bdok employs a risk-based approach to identify, assess, and mitigate risks associated with customers and transactions. Customers are categorized into risk levels based on information collected through KYC, transaction patterns, geolocation, and other relevant indicators. The primary categories are Low Risk and High Risk. High-Risk status triggers Enhanced Due Diligence (EDD) procedures and additional verification steps as described in this policy.

Know Your Customer (KYC) and Verification

Bdok requires identification and verification before permitting a customer to participate in any betting or gaming activity involving monetary funds. The following information is collected and verified during onboarding and periodically thereafter as part of ongoing monitoring:

• Date of birth or age confirmation, showing the customer is at or above the applicable legal age of majority.
• Full legal name and residential address.
• Email address and a username for Bdok account access.
• Unique identifiers such as a government-issued document (passport, national ID, or equivalent) and a second document to verify identity where required.
• Proof of address (recent utility bill, bank statement, or equivalent document).
• Payment details sufficient to link the customer to the account for monitoring and verification purposes.
• IP address and geolocation data to confirm that the customer is located in a permitted jurisdiction at the time of registration and when accessing Bdok services.

Bdok may request additional documentation to complete verification or to resolve discrepancies. A customer account may be placed on hold or terminated if information provided is false, misleading, or unverifiable. Bdok reserves the right to refuse opening or to close an account at its discretion following a review of KYC information.

Standard and Enhanced Due Diligence

Standard Due Diligence (SDD) applies to all customers initially. Enhanced Due Diligence (EDD) is applied to customers identified as High Risk or when suspicious or irregular activity is detected. EDD may include:

• Additional identity verification, such as a clearly legible copy of an identity document and a selfie with the document.
• Supplementary proof of address and verification of the source of funds or wealth.
• Direct verification engagements by Bdok’s compliance team, including telephone verification or additional documentation requests.
• Ongoing monitoring and periodic review of the customer’s activity, limits, and geographic location.

EDD is also triggered by indicators such as residence in a High-Risk Jurisdiction, suspected structuring of deposits, suspected use of multiple identities, or involvement in activity that suggests collusion or market manipulation.

The Money Laundering Reporting Officer (MLRO)

Bdok designates an MLRO who is responsible for compliance with AML/CFT regulations, the oversight of KYC information, monitoring of customer activity, and reporting to the competent authorities. The MLRO maintains records of all suspicious activity and co-operates with regulatory bodies, law enforcement, and other authorities as required by law.

Monitoring of Account Activity

Bdok maintains automated transaction monitoring systems and manual review processes to detect irregular, suspicious, or fraudulent activity. Signals may include unusual deposit patterns, rapid deposit-withdrawal cycles, or activity inconsistent with a customer’s profile. When such signals arise, Bdok classifies the customer as High Risk and applies appropriate monitoring and, if warranted, EDD procedures.

Unusual or Suspicious Activity and Reporting

Bdok is obligated to report suspicious transactions or activities to the relevant financial intelligence authority. The MLRO determines whether a report is required and ensures that records of all such determinations are maintained. Where required by law, Bdok will preserve a detailed record of the basis for any decision not to report a transaction.

Account Security and Access

Bdok enforces strict controls to prevent access by unauthorized parties. Account access is restricted to the customer registered with the Bdok account. Sharing login credentials or access links is prohibited, and Bdok may suspend or terminate a customer account if there is reasonable evidence of credential sharing or misuse.

Multiple Accounts and Collusion

Bdok prohibits multiple Bdok accounts per individual, household, or shared environment. If Bdok detects or suspects the creation of multiple accounts or collusion between customers to gain an advantage, Bdok will suspend related accounts, conduct an investigation, and may withhold funds and winnings pending resolution. Bdok reserves the right to close any account and deny future access if misuse is confirmed.

Withdrawals and Payouts

Withdrawals must be requested via a verified Bdok account. Bdok will review the account for unusual activity prior to processing withdrawals and may require additional KYC verification or documentation. Funds will only be transferred to the registered customer’s account and in the name of the registered customer. Bdok may withhold funds, suspend the account, or terminate the account and report activity to the relevant authorities if suspicious activity is detected or if documentation is incomplete or unverifiable.

Cryptocurrency Transactions

For Bdok platforms that support cryptocurrency, the following rules apply: the initial deposit must be made using a supported cryptocurrency. All subsequent deposits, wagers, and payouts must be conducted using the same cryptocurrency. Bdok does not provide exchange services between cryptocurrency and fiat currency. To comply with AML/CFT requirements, Bdok shall collect and verify customer identity, age, and address, and retain identity verification data at all times. The platform shall display the prevailing exchange rate for the supported cryptocurrency on the homepage. Customers should be aware that cryptocurrency values fluctuate and are not guaranteed by Bdok. Deposits and withdrawals must be traceable to the same customer and Bdok reserves the right to block or require additional verification if activity appears inconsistent with the customer profile.

Data Privacy, Retention, and Data Controller

Bdok processes personal data in accordance with applicable data protection laws. A Bdok data controller is responsible for data processing, security, and retention. Personal data collected through registration and use of Bdok services will be retained for a minimum period of eight (8) years unless a longer retention period is required by law. Customers have rights to access, rectify, or erase their data where permitted and may exercise these rights by contacting Bdok’s data protection contact. Bdok uses reasonable technical and organizational measures to safeguard personal data and to prevent unauthorized access, alteration, disclosure, or destruction.

Retention of Records

Bdok maintains KYC records, transaction histories, and monitoring logs for a minimum of eight (8) years from the date of the last activity or as otherwise required by applicable law, regulation, or regulator expectations. Records include identity documents, source of funds information, and the results of all due diligence checks performed.

Compliance Training and Governance

Bdok provides ongoing AML/CFT training to personnel with compliance responsibilities and conducts periodic audits of policies and procedures to ensure effectiveness. The MLRO oversees training, policy updates, and regulatory reporting requirements on an ongoing basis.

Effective Date and Updates

This policy is effective from the date published by Bdok and may be updated to reflect changes in law, regulation, or Bdok’s risk posture. Customers will be notified of material amendments in accordance with Bdok’s communications policy.