Scope and Legal Basis
The Anti-Money Laundering (AML) Policy of Mmk121 applies to all activities conducted on our platform, including customer acquisition, gameplay services, payment processing, and customer support. The Policy is designed to prevent money laundering and the financing of terrorism, and to ensure compliance with applicable AML/CFT laws and guidance issued by the regulator and international standards, including FATF recommendations.
Governance and Responsibility
Ultimate responsibility for AML compliance rests with the Director. The company maintains an AML Compliance Office responsible for day to day operations, policy maintenance, risk assessment, and reporting to the Board. The Board receives periodic updates on identified risks and control effectiveness.
Risk Management Framework
- Risk-based approach: controls scale with assessed risk across customer, product, interface, and geography.
- Initial onboarding risk assessment and ongoing reassessment at defined intervals; updates triggered by product launches, new markets, or regulatory changes.
- Documents retained and risk ratings determine due diligence requirements and monitoring intensity.
Know Your Customer and Identity Verification
On onboarding, Mmk121 verifies identity before any financial activity or account creation. Verification includes collecting personal data and documentary evidence, performing identity confirmation, and screening against sanctions, politically exposed persons and adverse lists. Age verification confirms the customer is at least 18 years old; underage gambling is prohibited.
- Acceptable documents include government issued photo IDs such as passport, national ID or driving license; proof of address may be requested (eg utility bill or bank statement dated within the last six months).
- Source of funds and source of wealth: customers provide explanation and documentary support for funds used to fund the account, with enhanced checks for unusual or large deposits.
- Record-keeping: all KYC data and supporting documents retained for a minimum of seven years after the end of the business relationship.
Enhanced Due Diligence and Ongoing Monitoring
High risk customers or activities trigger enhanced due diligence, including additional identity verification, ongoing monitoring of transactions, and periodic data refresh. Risk status updates occur as customers engage new products, enter new geographies, or changes in ownership or control arise.
Transaction Monitoring and Reporting
The platform monitors transactions for indicators of money laundering or terrorist financing, including unusual payment patterns, rapid fund movements, or inconsistent source of funds data. Any suspicious activity or transactions above risk based thresholds requires immediate review and escalation to the AML Compliance Officer and, where required by law, reporting to the competent authority.
Record Keeping
All AML related records, including customer data, KYC documentation, risk assessments, due diligence decisions, internal reports, and SARs, are retained for at least seven years after the end of the relationship. Records remain accessible to the competent authority on demand in the event of an investigation.
Training and Awareness
All staff complete AML training at onboarding and receive annual refreshers. Training covers red flags, customer risk profiling, escalation procedures, and privacy safeguards.
Third-Party Relationships
AML due diligence applies to all third party service providers and affiliate arrangements; contractual obligations require compliance with this AML Policy; ongoing monitoring and escalation if suspicious activity is detected in third party relationships.
Data Privacy and Security
AML activities comply with data protection laws; access to personal data is restricted to authorized personnel; data is stored securely; data sharing occurs only as necessary for regulatory compliance and with appropriate safeguards.
Roles and Responsibilities
- Director: ultimate responsibility for AML policy; approves material changes and resources.
- AML Compliance Officer: implements day to day program; conducts risk assessments; oversees training; manages investigations; reports to the Board.
- Business Units: implement controls in customer interactions; ensure CDD and EDD is applied; coordinate with Compliance.
- IT and Data Security: maintain systems for identity verification, transaction monitoring, and data protection.
Suspicious Activity Indicators and Escalation
Red flags include unusual transaction patterns, rapid movement of funds, high risk jurisdictions, frequent small deposits or other activity designed to conceal true activity. All such indicators trigger internal escalation to the AML Compliance Officer and documentation in an internal report.
Periodic Review and Continuous Improvement
The policy is reviewed at least annually and after material regulatory changes. Findings are reflected in updates to procedures and controls. The Board receives risk dashboards and progress reports on training and remediation actions.
Contact and Escalation
For AML inquiries or to report suspicious activity, use the dedicated AML channel within the account management interface or contact the Compliance team through approved internal channels. All disclosures are treated confidentially and in compliance with applicable data privacy requirements.