Anti-money Laundering Policy

Purpose and scope

Shuvo777 maintains this AML/CFT policy to prevent and detect money laundering and the financing of terrorism within its gaming operations. It applies to all personnel, contractors, and systems under Shuvo777 and governs onboarding, ongoing account activity, and financial flows facilitated by the platform.

Regulatory framework and governance

The policy aligns with FATF guidance and applicable AML/CFT laws and licensing requirements in the jurisdictions where Shuvo777 operates. Ultimate responsibility rests with the Board, with day-to-day administration carried out by the Compliance Function, headed by the designated AML/CFT Compliance Officer who oversees implementation, training, monitoring, and reporting.

Risk-based approach and risk assessment

• Shuvo777 uses a risk-based framework to identify and manage ML/FT risk across customer, product, geography, and channel dimensions.
• On onboarding and at defined intervals, a risk assessment determines appropriate due diligence levels and controls.
• Elevated risk triggers enhanced controls; low risk allows streamlined processing consistent with minimal data collection.

Know Your Customer and due diligence

Onboarding customers undergo identity verification before accessing real money features. The level of due diligence is determined by risk. At a minimum, the following information must be collected and verified during onboarding:

• Account holder identifiers such as full name, date of birth, address, and contact details.
• Proof of identity through a government-issued document; verification confirms the name matches the account holder and the document is valid.
• Proof of address showing residence within the past three months.
• Evidence of control of the payment instrument used to fund the account and, where applicable, the source of funds.

Initial and ongoing due diligence is conducted on a risk basis, with Simplified Due Diligence applied for low-risk cases and Standard Verification triggered when cumulative gaming transactions reach or exceed 1,000 USD. Ongoing due diligence ensures information remains current throughout the relationship.

Enhanced due diligence for high risk and politically exposed persons

For users presenting elevated ML/FT risk, including PEPs or residents of high-risk jurisdictions, Shuvo777 requires enhanced verification. This includes additional documentation, disclosure of sources of wealth and funds, and, where necessary, senior management approval prior to continuing the relationship. The company may suspend or deny access if requirements are not met.

Transaction and activity monitoring

Shuvo777 monitors deposits, transfers, and withdrawals for unusual or suspicious patterns. Indicators include, but are not limited to:

• Excessive deposit activity relative to known history;
• Use of multiple payment instruments within a short period;
• Geographic or device changes inconsistent with the customer profile;
• Discrepancies between geolocation data, IP address, and registered information;
• Refusal to provide verification or disclosure of ownership of funds.

Any suspicious activity identified by monitoring is escalated to the AML/CFT compliance team for assessment and, if warranted, reported to the competent authority in accordance with legal obligations.

Record-keeping and data protection

Shuvo777 retains identification documents, transaction data, and supporting evidence for a period required by applicable law, typically not less than five years after the end of the customer relationship. All data handling complies with relevant data protection laws and internal privacy policies, with access restricted to authorized personnel and stored securely.

Training and awareness

Staff receive AML/CFT training on onboarding and on an ongoing basis, with updates issued promptly in response to policy changes, new products, or regulatory developments. Training covers identification of suspicious activity, escalation procedures, and regulatory reporting obligations.

Suspicious activity reporting and cooperation with authorities

All suspicious activity is reported through the internal compliance channel. When required by law, the compliance function files reports with the competent authorities in a timely manner, providing all information gathered through due diligence, monitoring, and records. Cooperation with inquiries and investigations continues as required by applicable laws.

Policy changes and communication

This policy may be revised by Shuvo777 at any time. Material changes will be communicated to customers and staff via secure channels. Continued use of services constitutes acceptance of updated terms in accordance with applicable law and regulation.

Definitions

• Money laundering refers to concealing the origins of illicit funds or engaging in transactions designed to disguise such origins.
• Financing of terrorism means providing financial support to individuals or groups involved in terrorism.
• Know Your Customer denotes the processes used to verify identity and assess risk.
• Politically Exposed Person or PEP denotes an individual who holds or has held a prominent public function, including close family and associates.
• Enhanced due diligence means intensified verification and monitoring for higher risk customers or transactions.