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Winshark implements this KYC Policy to identify, verify, monitor, and manage customer risk in compliance with applicable AML/CFT obligations. This Policy applies to all applicants and customers accessing Winshark services and governs onboarding, ongoing activity, and escalation procedures related to customer due diligence.
Winshark operates as a remote gaming entity regulated by the competent supervisory authority and is subject to anti-money laundering and countering the financing of terrorism requirements. Ultimate responsibility for the AML policy rests with the Director. The Compliance Function maintains, reviews, and updates the policies, procedures, and controls. The Board receives regular reporting on risk, compliance effectiveness, and the status of controls.
Customer Due Diligence (CDD) refers to the processes for identifying and verifying customers and assessing risk. Enhanced Due Diligence (EDD) applies in higher‑risk scenarios in accordance with the risk assessment. Ongoing monitoring means continuous review of customer activity against verified information. Non-face-to-face onboarding is subject to the same verification standards as in-person onboarding.
CDD is conducted before accepting a customer relationship. On onboarding, Winshark collects information sufficient to establish identity and risk context and to determine the appropriate level of due diligence:
Verification must be satisfactory prior to acceptance of the customer as a client. Where non-documentary verification is used, the methods must be reliable and independently verifiable.
Winshark applies a risk-based approach to CDD and ongoing monitoring. The level of due diligence and monitoring is commensurate with identified risk. Enhanced due diligence is applied for higher‑risk profiles, including circumstances identified by the risk assessment such as elevated geographic or activity risk or unusual transaction patterns, subject to additional verification steps as determined by the risk evaluation.
Customer information and risk profiles are reviewed on an ongoing basis. An initial due diligence baseline is maintained and refreshed at intervals defined by risk category and in response to material changes in the customer’s profile or activity. Winshark may request supplementary documentation when risk factors change or transactions deviate from expected patterns.
Winshark maintains records of all identity verification, risk assessments, due diligence, and transaction monitoring for the period required by applicable law and regulatory guidance. Records must be readily retrievable for audit or regulatory inspection. Suspicious activity or transactions discovered or suspected must be reported through the internal escalation process and, where required by law, reported to the competent authorities in a timely manner.
All personnel must complete AML/CFT training appropriate to their role upon recruitment and at least annually thereafter. Training covers recognition of red flags, customer risk indicators, and escalation procedures.
For onboarding conducted without physical presence, Winshark conducts identity verification using reliable, independent sources and retains evidence of verification. The same standard of due diligence applies as for in-person onboarding, including ongoing monitoring and document retention obligations.
Winshark maintains a responsible gaming program and honors valid self-exclusion requests. Self-exclusion applies across all products and services and is integrated with the customer verification and account-restriction workflows.