WinWin KYC & AML Policy

The Know Your Customer (KYC) and Anti-Money Laundering (AML) policy of WinWin sets out how identity check, ID verification, and account protection are handled for users in Bangladesh. This policy explains the security measures applied to reduce financial crime risks, meet regulatory requirements, and support user safety and responsible gaming across all casino and sportsbook services.

Purpose of KYC & AML

KYC and AML procedures are applied to verify each account holder, confirm the legitimacy of funds, and detect suspicious activity that may indicate money laundering or terrorist financing. These controls help the platform follow applicable laws in Bangladesh and maintain fair play and transparency in all gaming and betting activities.

The KYC and AML framework is designed to provide the following guarantees:

  • Fair play based on verified user identities and lawful sources of funds
  • User safety through early detection of suspicious activity and attempted fraud
  • Transparency in how personal data is collected, used, and retained for identity check and document submission
  • Compliance with AML, CTF, and other regulatory requirements in Bangladesh
  • Account protection through continuous security measures on logins, payments, and withdrawals
  • Consistent application of responsible gaming rules to all verified users

KYC Requirements

Every new user must complete identity check and ID verification before full access to deposits, betting, and withdrawals is allowed. Additional document submission may also be required later if risk indicators or regulatory obligations arise.

During KYC review, the following categories of documents may be requested:

  • Government-issued photo identification (for example, national ID card, machine-readable passport, or driving licence) to confirm name, age, and nationality of the account holder
  • Proof of residential address (for example, utility bill, bank statement, official correspondence, or digital statement from a regulated provider) showing full name and recent address in Bangladesh or another declared country
  • Confirmation of ownership of payment methods used on the platform (for example, partial screenshot of bank account, mobile financial service account, or card statement) to verify that deposits and withdrawals belong to the same account holder
  • Any additional supporting document requested under local regulatory requirements, risk-based reviews, or enhanced due diligence checks

Document submission may be requested again if details change, personal data appears inconsistent, or the initial copies are no longer valid or legible.

AML Measures and Security Measures

The platform implements structured AML controls and security measures to prevent the misuse of gaming and sportsbook services for money laundering, terrorist financing, or other illegal conduct. These measures support continuous transaction monitoring, user safety, and compliance with reporting obligations under Bangladeshi law.

The main AML and counter-terrorism financing measures include:

  • Ongoing transaction monitoring of deposits, bets, transfers, and withdrawals to detect patterns that may indicate suspicious activity
  • Automated detection rules and risk-based filters that flag unusual behaviour, rapid balance movements, or inconsistent document submission
  • Enhanced due diligence for higher-risk events, such as large volume play, cross-border transactions, or use of complex payment methods
  • Manual reviews of large or unusual transfers, including repeated failed deposits or cash-out requests inconsistent with a user’s profile
  • Risk scoring of accounts based on factors like geography, product usage, payment behaviour, and historical alerts
  • Sanctions screening and politically exposed person (PEP) checks where required, supported by independent databases or external providers
  • Timely reporting of suspicious transactions or accounts to competent authorities, where required by applicable AML and CTF laws in Bangladesh
  • Periodic review and updating of AML procedures, including staff training, to keep controls aligned with current legal and regulatory requirements

Prohibited Activities Supporting KYC & AML Controls

To keep the platform compliant and protect users, certain behaviours and account activities are strictly forbidden. These restrictions support effective identity check, document submission, transaction monitoring, and broader AML safeguards.

The following activities are prohibited:

  • Opening or operating multiple accounts for the same person, including attempts to bypass limits or duplicate bonuses
  • Using forged, altered, stolen, or misleading identification or address documents during ID verification or later reviews
  • Any attempt to use the platform to transfer, layer, integrate, or otherwise disguise proceeds of crime or funds linked to terrorism financing
  • Manipulating game systems, betting markets, or payment flows to create artificial balances, recycled funds, or fake winnings
  • Sharing, selling, renting, or otherwise allowing third parties to access or control an account, regardless of relationship to the account holder
  • Depositing or withdrawing through payment instruments that belong to another person or entity, unless permitted under explicit legal and platform rules
  • Providing false identity information, using a name of another individual, or misrepresenting beneficial ownership of funds or accounts
  • Circumventing technical, geographical, or transactional limits designed to support AML, CTF, and responsible gaming controls

Consequences of Non-Compliance

Breaches of this AML and KYC policy, refusal to provide required personal data, or involvement in suspicious activity can result in immediate enforcement action. Measures are applied in a proportionate manner, in line with legal and regulatory requirements in Bangladesh.

Possible consequences include temporary or permanent account suspension, freezing or confiscation of funds linked to suspicious activity, cancellation of bets or winnings, reporting to competent authorities where applicable.

User Responsibilities Under KYC & AML Rules

Every user is responsible for providing complete, accurate, and up-to-date personal data during registration and throughout the life of the account. Identity check and document submission requests must be completed promptly so that ID verification, transaction monitoring, and other security measures can operate correctly.

Users must respond to requests for additional documents or clarifications in a timely manner, and must not provide information or images that are altered, misleading, or belong to another person. Only payment methods owned and controlled by the same account holder may be used for deposits and withdrawals, subject to any additional limits set under local banking and payment rules.

Users are expected to monitor their own accounts for irregularities and inform customer support immediately if suspicious activity, unauthorised transactions, or potential data breaches are noticed. Responsible gaming practices should be followed at all times, including use of limits and self-exclusion tools where needed, to keep financial behaviour consistent and manageable.

Failure by users to cooperate in KYC or AML checks may lead to restricted services, delayed withdrawals, or other actions required to meet regulatory requirements and reporting obligations.

Fair Play and Transparency Commitments

The platform is committed to fair play and transparency so that all users in Bangladesh can participate in gaming and betting in a safe, controlled environment. These commitments cover how identity check is handled, how personal data is safeguarded, and how suspicious activity is detected and managed.

Key principles include:

  • Full alignment of KYC, ID verification, and AML procedures with applicable legal and regulatory requirements in Bangladesh
  • Confidentiality and strong protection of personal data gathered for account opening, document submission, and ongoing monitoring
  • Continuous transaction monitoring and review of behaviour patterns to identify and address suspicious activity in a timely manner
  • Prevention of manipulation, collusion, and any other unfair behaviour that could affect betting outcomes or the fairness of casino games
  • Dedicated user support to explain security measures, AML checks, account protection steps, and responsible gaming tools
  • Shared responsibility between the platform and each account holder in maintaining user safety and protecting the integrity of financial transactions
  • Equal conditions, consistent enforcement of rules, and non-discriminatory treatment for all users subject to the same KYC and AML standards

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