Anti-Money Laundering and Know Your Customer Policy

WinWin operates under stringent regulatory requirements to prevent financial crime and ensure the protection of all users in Bangladesh. The platform implements comprehensive identity verification and transaction monitoring protocols to detect and prevent money laundering, fraud, and terrorist financing. These measures safeguard account holders, maintain fair play, and uphold the integrity of the gaming environment.

Objectives of Identity Verification and Financial Crime Prevention

The platform applies robust identity check procedures and transaction monitoring systems to verify account holders, prevent fraudulent activity, and combat financial crime. These protocols ensure regulatory compliance and maintain a secure environment for all users.

  • Fair Play: All participants engage under equal conditions, with no advantage granted through fraudulent means.
  • User Safety: Personal data and financial transactions receive protection through advanced security measures.
  • Transparency: The platform operates openly, informing users of verification requirements and monitoring activities.
  • Regulatory Requirements: All procedures align with applicable laws and industry standards in Bangladesh.
  • Account Protection: Verification processes prevent unauthorised access and identity misrepresentation.

Identity Verification Requirements

Every new account holder must complete the verification process before accessing full platform functionality. The platform may request specific documents to confirm identity and comply with regulatory obligations.

  • Government-Issued Photo Identification: Valid national identity cards, passports, or driver’s licences bearing the user’s photograph and date of birth.
  • Proof of Residential Address: Utility bills, bank statements, or official correspondence issued within the last three months.
  • Payment Method Confirmation: Documentation demonstrating ownership of deposit or withdrawal instruments, such as bank account statements or payment card images (with sensitive details obscured).
  • Additional Documents: In certain circumstances, supplementary records may be requested to satisfy enhanced due diligence requirements.

Anti-Money Laundering Controls

The platform maintains comprehensive controls to detect and prevent money laundering, terrorist financing, and other illegal activities. These systems operate continuously to identify suspicious patterns and ensure compliance with reporting obligations.

  • Transaction Monitoring: All deposits, withdrawals, and betting activity undergo automated review to detect unusual patterns or behaviours.
  • Automated Detection Rules: Risk-based algorithms flag transactions that deviate from normal user behaviour or exceed predefined thresholds.
  • Enhanced Due Diligence: High-value transactions, large withdrawals, or atypical activity trigger additional verification steps and manual review.
  • Review of Unusual Transfers: Payments involving uncommon methods, irregular amounts, or rapid fund movement receive heightened scrutiny.
  • Risk Scoring Systems: Each user account receives a dynamic risk assessment based on transaction history, geographic factors, and behavioural indicators.
  • Sanctions and PEP Screening: Names are cross-referenced against international sanctions lists and databases of politically exposed persons.
  • Regulatory Reporting: Suspicious activity is reported to competent authorities in accordance with applicable laws and timelines.

Prohibited Activities

Certain actions undermine the integrity of verification processes and violate anti-money laundering standards. The platform strictly prohibits behaviours that compromise user safety or regulatory compliance.

  • Multi-Accounting: Creating or operating more than one account per individual to circumvent verification, bonuses, or betting limits.
  • Forged or Stolen Documents: Submitting falsified, altered, or unlawfully obtained identification materials during the verification process.
  • Money Laundering Attempts: Using the platform to transfer, convert, or conceal funds derived from illegal sources or activities.
  • System Manipulation: Exploiting technical vulnerabilities, automated tools, or coordinated strategies to distort transaction records or betting outcomes.
  • Account Sharing or Sales: Granting access to login credentials, transferring account ownership, or selling verified accounts to third parties.
  • Third-Party Payment Instruments: Depositing or withdrawing funds using payment methods not registered in the account holder’s legal name.
  • Identity Misrepresentation: Providing false personal data, using another person’s details, or concealing true identity during registration or verification.

Consequences of Non-Compliance

Violations of verification requirements or anti-money laundering standards result in immediate enforcement actions. The platform may impose temporary or permanent account suspension, freeze or confiscate funds linked to suspicious activity, cancel bets or winnings derived from prohibited behaviour, and report the matter to competent authorities where applicable under regulatory obligations.

Responsibilities of Account Holders

Users bear the obligation to ensure compliance with all verification and monitoring requirements. Account holders must provide accurate and current personal data during registration and update this information promptly when circumstances change. Verification requests require timely responses, including the submission of requested documents within specified deadlines. Only payment methods registered in the user’s legal name may be used for deposits or withdrawals. Users must report any suspicious activity observed on their accounts or within the platform environment. Failure to fulfil these responsibilities may result in restrictions or account closure.

Fair Play and Transparency Principles

The platform upholds rigorous standards of fair play and transparency to protect all users and maintain a secure gaming environment. These principles guide every aspect of verification, monitoring, and enforcement activities.

  • Compliance with Standards: All procedures adhere to applicable anti-money laundering regulations, identity verification protocols, and industry best practices.
  • Confidentiality and Data Protection: Personal data collected during verification undergoes encryption and secure storage, accessible only to authorised personnel for legitimate purposes.
  • Ongoing Monitoring: Continuous review of user activity detects emerging risks, suspicious patterns, or behavioural anomalies requiring intervention.
  • Prevention of Manipulation: Systems identify and block attempts to exploit bonuses, manipulate odds, or engage in coordinated betting schemes that undermine fairness.
  • User Support on Safety Matters: Dedicated assistance addresses questions regarding document submission, verification status, or account security concerns.
  • Shared Responsibility: Maintaining a safe and compliant environment requires cooperation between the platform and its users, with each party fulfilling their respective obligations.
  • Equal Conditions for All: Verification and monitoring apply uniformly, ensuring no user receives preferential treatment or exemptions from regulatory requirements.

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