AML

AML Statement of GT7 Limited

Effective Date: 07.07.2025

Last Updated: 07.07.2025

Operated by GT7 Limited

Registration Number: 000044449

Registered Address: 123 Barrack Road, Belize City, Belize

License Number: LSI-202504041-FI2

Regulator: Government of the Autonomous Island of Anjouan, Union of Comoros

At Moonbet we are committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. As a licensed and regulated operator, we place the utmost importance on protecting our platform from being misused for money laundering, terrorist financing, or any form of financial crime. To this end, we have implemented a robust Anti-Money Laundering (AML) framework aligned with international best practices and applicable regulations.

To ensure the integrity of our services and the legitimacy of user activity, all users on Moonbet are required to complete a comprehensive three-step account verification process. This verification is mandatory and is designed to confirm the accuracy of the identity information provided, validate the ownership of payment instruments used for deposits and withdrawals, and assess potential AML risks associated with the customer’s jurisdiction, transaction behaviour, and payment method.

Verification thresholds and required documentation vary depending on a number of risk factors, including the user’s country of origin, deposit and withdrawal volume, and transaction patterns. The objective of this process is to protect our platform from illicit financial flows and to comply with evolving AML regulations in a risk-sensitive and proportionate manner.

Moonbet has adopted a risk-based approach to AML compliance and implements reasonable measures and technical controls to detect, mitigate, and manage risks associated with money laundering and related offences. This includes automated transaction monitoring systems, periodic customer reviews, and enhanced due diligence for higher-risk activities.

Our AML framework is founded on strict internal governance. The ultimate responsibility for the implementation and enforcement of AML policies rests with the senior management of GT7 Limited, who are fully committed to ensuring compliance across all levels of the organization. Day-to-day responsibility and oversight are delegated to a designated Anti-Money Laundering Compliance Officer (AMLCO), who reports directly to executive management and is empowered with the authority and independence required to fulfil this critical function.

The AMLCO is responsible for ensuring that policies and procedures are effectively implemented and kept up to date with relevant legislation. This includes staff training, internal audits, suspicious activity reporting, KYC enforcement, and cooperation with competent authorities and financial intelligence units, where necessary.

Definition of Money Laundering

For the purposes of this policy, money laundering includes, but is not limited to:

The conversion or transfer of property, particularly funds, knowing that such property is derived from criminal activity or participation therein, for the purpose of concealing or disguising its illicit origin, or of assisting any person involved in such activity to evade legal consequences.

The concealment or disguise of the true nature, source, location, disposition, movement, ownership, or rights concerning property, knowing it is derived from criminal activity or from participation therein.

The acquisition, possession, or use of property knowing, at the time of receipt, that it was derived from criminal activity or from assisting in such activity.

Participation in, facilitation of, or association with the commission, attempt, or support of any of the aforementioned activities.

It is important to note that money laundering is treated as a criminal offence even if the predicate criminal activity that generated the illicit funds occurred outside the jurisdiction in which the laundering is detected.

Moonbet remains fully committed to ensuring that its operations cannot be used to disguise the origin of illicit proceeds or to facilitate unlawful financial activity. Our AML program will continue to evolve in line with regulatory developments, technological advancements, and emerging risk trends.

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AML Policy Updates and Implementation

Any significant amendment to Moonbet’s Anti-Money Laundering (AML) Policy is subject to formal review and approval by the General Management of GT7 Limited and the Anti-Money Laundering Compliance Officer (AMLCO). Changes are only implemented following full internal assessment to ensure continued compliance with regulatory obligations and evolving international best practices. The AMLCO is responsible for coordinating the implementation of approved changes and updating all affected procedures and systems accordingly.

Customer Due Diligence – Three-Step Verification Process

To meet its obligations under AML and KYC regulations, Moonbet applies a three-step verification framework. This ensures appropriate risk-based due diligence for all users and establishes the legitimacy of payment instruments and account activity.

Step 1 – Basic Account Verification: all users must complete Step 1 verification prior to initiating any withdrawals, regardless of payment method, transaction amount, or nationality. This step involves completing a form through the user dashboard and submitting the following personal information: full legal name, date of birth, country of residence, gender, and complete residential address. This data is checked using automated tools and securely stored in our system.

Step 2 – Identity Verification: required when a user deposits over €2,000 or attempts to withdraw any amount. Users must submit a photograph of an official government-issued identity document (passport, national ID, or driver’s license), alongside a handwritten note displaying a six-digit random verification code provided by the platform. The information submitted during Step 1 is automatically cross-checked against two independent verification databases. If discrepancies are identified or if database verification is not possible, the user must submit a valid proof of residence, such as a government-issued certificate or recent utility bill.

Step 3 – Source of Wealth Verification: applies when a user deposits or withdraws over €5,000, or sends over €3,000 to another user. This step requires users to declare and document the origin of their funds. Acceptable sources of wealth include employment income, business ownership, inheritance, investment proceeds, or documented financial support from family. Supporting documents (such as payslips, tax returns, legal declarations, or investment statements) must be submitted. If these documents are not provided when requested, the user’s account may be temporarily frozen until verification is completed. Users are notified via email and in-app messaging. As an added safeguard, Moonbet may request the user to complete a transaction using a personal bank account or credit card to verify financial consistency.

Customer Identification (KYC) and Proof of Address

Formal customer identification is central to Moonbet’s onboarding process and broader compliance obligations. Customers must upload a government-issued identity document along with a handwritten note showing the verification code. A selfie is also required for biometric comparison. Non-essential details may be redacted to protect privacy, provided the following fields are clearly visible: first name, surname, gender, date of birth, nationality, and photo. All four corners of the ID must be visible, and the image must be clear and legible.

Users must upload a recent document (not older than 90 days) such as a utility bill, bank statement, or government letter showing their full name and residential address. Documents must be high-resolution, with all four corners visible and all text legible. Employees may perform further checks based on risk or data inconsistency.

Risk Scoring and Manual Review

All basic verification data is processed and stored using an identity verification system. The system analyses the consistency of submitted information and flags anomalies for review. Higher-risk users and flagged profiles are subject to manual verification by trained AML personnel.

In line with Moonbet’s risk-based approach, both automated and human oversight are applied. AI tools are routinely reviewed and recalibrated to detect evolving fraud patterns and regulatory risks, ensuring the platform remains secure, efficient, and compliant at all times.

Risk Management Framework

Moonbet implements a jurisdictional risk-based approach to user classification and transaction thresholds. All countries are categorised into one of three risk levels based on geographic risk assessments, international sanctions lists, AML enforcement standards, and internal due diligence considerations.

Low-Risk Jurisdictions (Tier 1): Uuers from low-risk countries follow the standard three-step verification process as outlined in our customer due diligence policy. This includes identity verification, proof of address, and—where applicable—source of wealth declarations.

Medium-Risk Jurisdictions (Tier 2): for users based in medium-risk countries, Moonbet applies more stringent verification thresholds. Step 2 verification becomes mandatory after deposits or withdrawals exceeding €1,000, or peer-to-peer transfers above €500. Step 3 (source of wealth) verification applies from €2,500 for deposits, withdrawals, or internal transfers. Additionally, users from low-risk jurisdictions who convert cryptocurrencies into other currencies may also be treated under Tier 2 due diligence requirements.

High-Risk Jurisdictions (Tier 3): Moonbet does not onboard users from countries classified as high risk. The list of high-risk jurisdictions is regularly reviewed and updated to remain in line with global AML trends, regulatory developments, and emerging geopolitical risks.

To ensure a secure flow of funds and prevent layering techniques, users are required to withdraw funds using the same payment method employed for the original deposit—at least for the equivalent value of the deposit—before any alternative withdrawal method is authorised.

Enterprise-Wide Risk Assessment (EWRA)

Moonbet conducts an annual Enterprise-Wide Risk Assessment (EWRA) to evaluate AML risk exposure across all operational layers of the business. This includes a comprehensive review of service offerings, user behaviour, transactional trends, onboarding channels, geographic exposure, and emerging financial crime risks.

The EWRA forms the foundation of our AML policy and defines risk thresholds, transaction monitoring logic, enhanced due diligence (EDD) triggers, and resource allocation. It is revised annually and in response to material changes in regulation, operational structure, or external risk climate.

Ongoing Transaction Monitoring

Moonbet enforces a multi-layered transaction monitoring system designed to identify suspicious behaviour, including deviations from established customer profiles. Monitoring is structured across three lines of control:

First Line of Control – Payment Service Provider (PSP) Oversight: we work exclusively with reputable, AML-compliant PSPs who perform their own initial due diligence, thereby mitigating risk before funds enter Moonbet’s system.

Second Line of Control – Internal Alerts & Profile Deviations: Moonbet’s compliance team monitors user activity through automated tools and human oversight. Any request related to financial activity (e.g. withdrawals, payment method changes, or account-level transactions) prompts real-time due diligence. The three-step verification process and associated risk parameters provide the compliance team with a comprehensive view of each customer’s transactional and behavioural footprint.

Third Line of Control – Manual Review of High-Risk Profiles: accounts displaying irregular or high-risk activity are subject to in-depth manual investigation. This includes analysis of transaction flows, behavioural anomalies, use of inconsistent payment instruments, or failure to justify financial sources. Any unexplained pattern—especially when lacking lawful documentation—is treated as a potential AML concern.

Transactions for which the origin or purpose cannot be reliably established are considered atypical and flagged for immediate escalation to the AML Compliance Officer (AMLCO). Staff are instructed to report any such activity without delay.

Suspicious Activity Reporting (SAR)

Internal procedures detail when and how employees must report suspicious activity. All reports of atypical or suspicious transactions are reviewed by the AML team. Based on this internal investigation, the AMLCO will determine whether a report should be submitted to the Financial Intelligence Unit (FIU) of the relevant jurisdiction.

In extreme cases, the AMLCO and senior management reserve the right to immediately terminate the business relationship with the user and restrict access to the account pending investigation.

Internal Procedures and Recordkeeping

Moonbet translates its AML policy into a detailed set of internal operating procedures, available to all relevant staff via the company’s secure intranet. These procedures outline the specific steps for identity verification, due diligence reviews, escalation processes, and reporting timelines.

Records obtained through KYC and AML procedures are retained securely in both encrypted offline and cloud-based environments. In accordance with regulatory requirements:

Identification data is stored for a minimum of 10 years following the termination of the customer relationship.

Transaction data is retained for at least 10 years from the date of the transaction or the last customer interaction.

Training and Awareness

All staff members involved in financial operations or customer onboarding are required to complete mandatory AML training. This includes:

Core training upon hire;

Annual refresher courses aligned with the latest regulatory and typology updates;

Advanced training for compliance staff and those engaged in high-risk reviews.

Training is delivered by AML professionals with practical expertise and is tailored to reflect the responsibilities of the trainees based on their business function.

Auditing and Quality Assurance

Moonbet’s internal audit function conducts regular independent reviews of the company’s AML and compliance controls. Audit reports are submitted to senior management and used to continually enhance the effectiveness of our framework. Findings from audits may also influence future changes to the EWRA or internal procedures.

Data Protection and Confidentiality

All customer data collected for AML/KYC purposes is handled in strict accordance with global privacy regulations. Moonbet does not sell, trade, or share customer data with third parties. Information will only be disclosed to external parties when legally required—such as to law enforcement, regulators, or designated AML authorities.

Moonbet fully complies with applicable data protection laws and applies encryption, access control, and secure storage procedures to protect all user data.

Contact Information

If you have any questions about this AML and KYC Policy, please contact us:

Email (General Inquiries): info@moonbet.casino

Email (Complaints or AML-related Issues): info@moonbet.casino