This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of ALJOBA LIMITADA ("the Operator"), which operates Axbet Casino at axbet-casino.nl, with respect to the detection, prevention and reporting of money laundering, terrorist financing and related financial crime. All registered players, account holders and persons interacting with the Axbet platform are subject to this Policy. Axbet is committed to maintaining the highest practicable standards of financial integrity and to ensuring that its services are never used as a vehicle for illicit activity.

1. Regulatory Framework and Licence

Axbet Casino is owned and operated by ALJOBA LIMITADA, operating under a Costa Rica gaming licence. Although Costa Rica provides the regulatory basis under which Axbet operates, the Operator voluntarily applies AML and KYC controls consistent with internationally recognised standards, including the Financial Action Task Force (FATF) Forty Recommendations and relevant European Union anti-money laundering directives, insofar as they represent best practice for online gambling operators serving an international player base.

The Operator reserves the right to update this Policy at any time in response to changes in applicable law, regulatory guidance or internal risk assessments. The most current version of this Policy is published on axbet-casino.nl and supersedes all previous versions from the date of publication.

2. Definitions

• AML — Anti-Money Laundering: the set of laws, regulations and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income.
• KYC — Know Your Customer: the process by which the Operator verifies the identity, address and, where applicable, the source of funds of its players.
• CDD — Customer Due Diligence: standard verification measures applied to all players.
• EDD — Enhanced Due Diligence: additional verification measures applied to higher-risk players, including politically exposed persons (PEPs) and those with complex financial profiles.
• PEP — Politically Exposed Person: an individual who holds, or has held within the preceding twelve months, a prominent public function, and their immediate family members and known close associates.
• SAR — Suspicious Activity Report: an internal report raised by the Operator's compliance function where money laundering or terrorist financing is suspected.
• MLRO — Money Laundering Reporting Officer: the designated senior individual responsible for overseeing AML compliance and receiving internal SARs.
• Player — any natural person who has registered or seeks to register an account at axbet-casino.nl.

3. Scope and Application

This Policy applies to:

• All players who register or attempt to register an account at axbet-casino.nl;
• All employees, contractors and agents of ALJOBA LIMITADA involved in operating or supporting the Axbet platform;
• All deposit and withdrawal transactions processed through the Axbet cashier, regardless of payment method;
• All bonus and promotional activity, including the ten-stage welcome package, the Highroller Bonus, and ongoing weekly promotions.

The Operator applies a risk-based approach, meaning that the intensity of due diligence is proportionate to the assessed level of risk presented by each player and each transaction.

4. Money Laundering — Overview and Stages

Money laundering is the process by which the proceeds of criminal activity are made to appear legitimate. It typically occurs in three stages:

• Placement — introducing criminal funds into the financial system, for example by depositing cash or using illicitly obtained funds to purchase casino credits.
• Layering — obscuring the trail of funds through complex transactions, transfers between accounts, or multiple rounds of gambling activity.
• Integration — reintroducing laundered funds into the legitimate economy, often in the form of winnings, withdrawals or refunds.

Axbet's controls are designed to detect and interrupt all three stages. No stage of the gambling or payment process is outside the scope of this Policy.

5. Customer Due Diligence (CDD)

5.1 When CDD Is Applied

The Operator applies CDD measures:

• At the point of account registration, before a player is permitted to deposit or play;
• When cumulative deposits, withdrawals or wagering activity reaches thresholds defined in the Operator's internal risk matrix;
• When a player requests a withdrawal of any amount, and before funds are released;
• When the Operator identifies a change in a player's risk profile or detects suspicious activity;
• At any other time the Operator deems appropriate at its sole discretion.

5.2 Standard Verification Documents

Players required to complete CDD must provide satisfactory copies of the following documents. All documents must be valid (not expired), clearly legible, and in colour:

The Operator may request certified or notarised copies of documents at its discretion and may engage third-party identity verification services to assist in document authentication.

5.3 Electronic Verification

Axbet may use automated electronic identity verification tools to cross-reference player-submitted data against publicly available and commercial databases. Electronic verification does not replace the Operator's right to request physical documentation at any time.

5.4 Consequences of Failing to Complete CDD

If a player fails to provide satisfactory documentation within the timeframe stipulated in the Operator's request, Axbet reserves the right to:

• Suspend the player's account and restrict access to all features, including deposits, withdrawals and gameplay;
• Withhold pending withdrawals until verification is satisfactorily completed;
• Permanently close the account in accordance with the Terms and Conditions published on axbet-casino.nl;
• Retain funds pending legal advice or regulatory direction where a suspicion of money laundering or fraud exists.

6. Enhanced Due Diligence (EDD)

6.1 Triggers for EDD

Enhanced Due Diligence is applied when standard CDD is insufficient to adequately assess the risk presented by a player. EDD is triggered by, but is not limited to, the following circumstances:

• The player is identified as a Politically Exposed Person (PEP) or is a close associate or family member of a PEP;
• The player's transaction patterns are inconsistent with their stated occupation or financial profile;
• The player deposits or withdraws amounts that approach or exceed the weekly limit of €5,000 or the monthly limit of €20,000 in a manner that raises concern;
• The player uses multiple payment methods in quick succession without clear legitimate justification;
• The player resides in, or transacts via, a jurisdiction identified as high-risk by FATF or equivalent bodies;
• An internal SAR has been raised in connection with the player's account;
• The player claims large winnings relative to their deposit and play history.

6.2 EDD Measures

EDD may include any combination of the following:

• Requests for Source of Funds (SOF) documentation, including payslips, tax returns, business accounts, dividend statements or evidence of asset sales;
• Requests for Source of Wealth (SOW) documentation explaining the origin of a player's overall financial position;
• Senior management approval before processing withdrawal requests;
• Increased monitoring frequency of all account activity;
• Third-party background screening and adverse media checks;
• Direct communication with the player to clarify the nature and purpose of specific transactions.

6.3 Politically Exposed Persons (PEPs)

Axbet treats all PEPs as higher-risk customers by default. Any player identified as a PEP, or who becomes a PEP during the course of their relationship with Axbet, is subject to mandatory EDD before any deposit is accepted or any withdrawal is processed. Senior management approval is required for the continuation of any business relationship with a PEP. PEP status is assessed using recognised commercial screening databases and is reviewed on an ongoing basis.

7. Ongoing Monitoring

Verification is not a one-time process. Axbet conducts ongoing monitoring of all player accounts throughout the duration of the customer relationship. Ongoing monitoring encompasses:

• Scrutiny of transactions to ensure consistency with the Operator's knowledge of the player's profile, including their stated occupation, financial status and typical gaming behaviour;
• Automated alerts triggered by unusual deposit or withdrawal patterns, including structuring (the deliberate splitting of transactions to avoid detection thresholds);
• Periodic re-verification of player identity and documentation, particularly where information held by the Operator is more than twelve months old;
• Review of player accounts following any change in circumstances, such as a significant increase in deposit frequency or average transaction size;
• Monitoring of bonus and promotional activity to detect patterns consistent with bonus abuse in conjunction with potential money laundering.

Where ongoing monitoring reveals a change in a player's risk profile, CDD or EDD measures will be applied or escalated accordingly.

8. Payment Methods and Financial Controls

Axbet supports a range of deposit and withdrawal methods, including Dutch banking providers (ABN AMRO, ING, Rabobank), Visa, Mastercard, Skrill, Neteller, Revolut, N26, Google Pay, Paysafecard, bank transfer, and cryptocurrency. The following financial controls apply across all methods:

The Operator reserves the right to delay or decline any transaction that raises a compliance concern, pending further investigation.

9. Suspicious Activity — Detection and Reporting

9.1 Indicators of Suspicious Activity

Axbet's compliance team is trained to identify indicators that may be consistent with money laundering or other financial crime. Examples include, but are not limited to:

• A player depositing funds rapidly up to the weekly limit of €5,000 or monthly limit of €20,000, with little or no actual gameplay;
• A player making multiple deposits just below apparent threshold levels in a short period (structuring);
• Requests to withdraw funds shortly after deposit, particularly where minimal wagering has occurred;
• Use of numerous different payment methods within a short timeframe without clear justification;
• Inconsistency between a player's stated identity or occupation and their transaction behaviour;
• Requests to change withdrawal method to one not previously associated with the account;
• Unusual interest in the mechanics of withdrawals, limits or compliance procedures;
• Account access from IP addresses associated with high-risk jurisdictions or known VPN/proxy services;
• Multiple accounts linked by common identifiers (IP address, device fingerprint, payment method, email domain);
• A player claiming large winnings that appear disproportionate to their wagering history.

9.2 Internal Reporting Procedure

Any employee or agent of ALJOBA LIMITADA who identifies or suspects suspicious activity must raise an internal Suspicious Activity Report (SAR) with the designated Money Laundering Reporting Officer (MLRO) without delay. Internal SARs must be submitted using the Operator's internal reporting channel and must not be communicated to the player concerned (tipping-off). The MLRO will assess each SAR and determine whether it warrants escalation to the relevant competent authority.

9.3 Tipping-Off Prohibition

It is a serious breach of this Policy — and, where applicable, of the law — to inform any player, third party or unauthorised individual that a SAR has been filed, that an investigation is underway, or that a player's account is subject to enhanced scrutiny. All staff are required to maintain strict confidentiality in relation to any compliance investigation.

10. Record Keeping

The Operator maintains comprehensive records in connection with its AML and KYC obligations. Records retained include:

• Copies of all identity and verification documents submitted by players;
• Records of all CDD and EDD measures applied, including the date, nature and outcome of each check;
• Full transaction histories for all player accounts, including deposits, withdrawals, bonuses and wagering activity;
• Copies of all internal SARs raised and the MLRO's assessment of each;
• Records of all correspondence with players in connection with verification requests;
• Risk assessments and screening results produced in connection with individual accounts.

All records are retained for a minimum of five (5) years from the date of the last transaction or the closure of the account, whichever is the later. Records may be retained for longer periods where required by applicable law or ongoing legal proceedings. All records are stored securely in accordance with the Operator's data protection obligations.

11. Risk-Based Approach

Axbet applies a risk-based approach to AML and KYC compliance. This means that the level of due diligence applied to any given player or transaction is calibrated to the risk that player or transaction presents, rather than applying a uniform process to all cases. The Operator's risk assessment takes into account:

• Player risk — nationality, jurisdiction of residence, occupation, PEP status, adverse media profile;
• Product risk — the nature of the game type, betting limits, and whether bonuses are being claimed;
• Channel risk — the payment method used, the device and IP address from which the account is accessed;
• Geographic risk — whether the player is located in, or transacting from, a jurisdiction identified as presenting a higher risk of money laundering or terrorist financing.

Risk assessments are documented and reviewed periodically or whenever a material change in a player's circumstances is identified.

12. Staff Training and Awareness

All employees and contracted personnel of ALJOBA LIMITADA who are involved in the operation of axbet-casino.nl receive AML and KYC training commensurate with their role. Training covers:

• The legal and regulatory framework governing AML obligations;
• Recognition of the indicators and red flags of money laundering and terrorist financing;
• The Operator's internal SAR procedure and the role of the MLRO;
• The tipping-off prohibition and confidentiality requirements;
• Record-keeping obligations;
• Responsible gambling and player protection obligations as they intersect with compliance activity.

Training is provided upon commencement of employment and refreshed at regular intervals, or sooner if there are material changes to this Policy or the applicable regulatory environment.

13. Interaction with Responsible Gambling Obligations

Axbet recognises that AML compliance and responsible gambling obligations are complementary. A player who exhibits signs of problem gambling — such as rapid, repeated deposits approaching the daily or weekly limits, or unusual loss-chasing behaviour — may simultaneously trigger AML monitoring protocols. In such cases, both the compliance function and the responsible gambling function will be engaged concurrently, and the welfare of the player will not be subordinated to financial crime concerns, nor vice versa.

Players can access responsible gambling tools directly through their account on axbet-casino.nl. These tools include deposit limits, session time controls, self-exclusion, and cooling-off options. The availability of these tools does not limit the Operator's right to impose additional restrictions for compliance purposes.

14. Account Closure and Fund Retention

Where the Operator determines, following investigation, that a player's account has been used in connection with money laundering, fraud, or any other financial crime, Axbet reserves the right to:

• Immediately and permanently close the account without prior notice;
• Freeze and withhold any funds held in the account pending the outcome of an investigation;
• Report the matter to the relevant law enforcement or competent authority;
• Retain funds in compliance with a direction from law enforcement or a competent authority;
• Refuse to process any withdrawal request where the legitimacy of the funds in question cannot be established to the Operator's satisfaction.

The Operator will not be liable to the player for any loss, inconvenience or damage arising from account suspension, fund retention or account closure carried out in good faith pursuant to this Policy.

15. Data Protection and Confidentiality

All personal data collected in the course of CDD, EDD and ongoing monitoring is processed in accordance with the Operator's Privacy Policy, published on axbet-casino.nl. Data is collected solely for the purposes of compliance with this Policy and is not shared with third parties except where required by law, by regulatory direction, or for the purpose of conducting lawful compliance checks using approved third-party screening services. Players retain the right to access their personal data subject to applicable law; however, the Operator may restrict access to specific records where disclosure would impede an ongoing investigation or violate the tipping-off prohibition.

16. Amendments to This Policy

ALJOBA LIMITADA reserves the right to amend, update or replace this Policy at any time. Material changes will be published on axbet-casino.nl. Continued use of the platform following the publication of an updated Policy constitutes acceptance of the revised terms. Players are advised to review this page periodically to ensure they are familiar with the current version.

17. Contact and Compliance Enquiries

Players with questions regarding this Policy, or who wish to submit documentation in connection with a verification request, should contact the Axbet support team via the 24/7 live chat facility or by email, both of which are accessible from axbet-casino.nl. Support is available in English and French. The Operator aims to respond to all compliance-related correspondence promptly and to complete standard KYC reviews within a reasonable timeframe, subject to the player providing all required documentation without delay.