Aml

1. Scope and Regulatory Framework

Slott maintains an AML/CFT program designed to prevent, detect, and report money laundering and the financing of terrorism. The program applies to all gaming, payments, and related financial activities conducted through the Slott platform and is implemented in accordance with applicable laws, regulatory guidance, and internationally recognized standards, including FATF recommendations and relevant local regulations.

2. Governance and Oversight

The Board of Slott bears ultimate accountability for the integrity of the AML/CFT program. The Compliance Officer, reporting to the Board, is responsible for policy development, risk assessment, staff training, and monitoring the efficacy of controls. The Internal Audit function provides independent assurance, reviews control adequacy, and coordinates corrective actions when deficiencies are identified.

3. Risk Assessment

A risk-based approach informs all AML/CFT activities. The Company identifies, evaluates, and prioritizes inherent and residual risks arising from customers, products, channels, and geographies. Key factors include:

  • Customer profile: casual players and high-rollers, with enhanced scrutiny for high-risk or politically exposed individuals.
  • Product risk: online casino games and sports betting, with particular attention to betting patterns and unusual wager structures.
  • Payment methods: traditional methods, digital wallets, and cryptocurrencies; privacy-centric instruments attract heightened monitoring.
  • Geographic risk: screening for customers from or transacting with restricted or high-risk jurisdictions.

Controls include Enhanced Due Diligence (EDD) for high-risk customers, transaction limits, ongoing reviews of high-risk accounts, and independent audits. The risk assessment is reviewed at least annually or upon material changes in operations, customer behavior, or regulatory requirements.

4. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

On onboarding, Slott collects validated information to verify identity and assess risk. Required data includes:

  • Full legal name
  • Date of birth
  • Residential address
  • Nationality
  • Government-issued identification

Verification is performed using automated identity verification and manual review where necessary. Sanctions and watchlist screening is conducted on all customers. Customer tiers are defined as:

  • Simplified Due Diligence for low-risk profiles
  • Standard Due Diligence for the majority of customers
  • Enhanced Due Diligence for high-risk profiles, including source-of-funds checks and biometric verification

Ongoing monitoring of customer activity is conducted, with records of all CDD actions retained for no less than five years from the end of the relationship or the date of the last transaction, whichever is later.

5. Transaction Monitoring and Investigations

Slott employs real-time transaction monitoring to identify patterns that diverge from established customer behavior. Monitoring criteria include transaction size, frequency, deviations from expected activity, and trigger events such as rapid deposits and withdrawals. Suspicious activity is escalated for review by the Compliance team, with the following procedures:

  • Correlation with KYC data and historical transaction patterns
  • Assessment of source of funds and legitimacy of funds
  • Where applicable, use of blockchain analytics for cryptocurrency transactions
  • Structured investigations leading to documented determinations

If activity is confirmed as suspicious, a Suspicious Activity Report (SAR) is prepared and filed with the appropriate supervisory or regulatory authority in accordance with applicable law. The Company preserves all SARs and related records for the statutory retention period.

6. Sanctions Compliance and Prohibited Jurisdictions

Slott regularly screens customers and transactions against current sanctions lists and maintains a prohibited or high-risk jurisdiction list. Where a match or risk is identified, the Company will:

  • Place an immediate hold on the customer account or transaction
  • Initiate an internal investigation and enhanced due diligence as appropriate
  • Report the incident to the relevant authorities in accordance with legal requirements

False positives are managed through a documented review process to confirm genuine matches before any action is taken. Compliance with sanctions regimes is continuous and contemporaneous with business operations.

7. Education and Training

All employees undergo AML/CFT training during onboarding and participate in annual refresher programs. Training covers red flags, KYC/CDD procedures, transaction monitoring, and incident response. Specialized training is provided for roles with heightened risk, including compliance and risk management staff.

8. Reporting

Slott enforces a structured reporting framework to ensure timely escalation of suspicious activity. Internal escalation paths channel concerns to the Compliance Officer, who coordinates external reporting to the competent authorities as required by law. Documentation of red flags, investigations, and final determinations is maintained in accordance with record-keeping obligations.

9. Data Retention and Privacy

Data collected for AML/CFT purposes is processed in accordance with applicable data protection laws. Records relating to customer due diligence, transaction monitoring, and investigations are retained for a minimum of five years following the end of the relationship or the last relevant transaction, unless a longer period is required by law. Access to retained data is restricted to authorized personnel and governed by policy controls to ensure confidentiality and security.

10. Third-Party Management

When engaging third-party service providers or payment processors, Slott conducts due diligence to assess AML/CFT controls, data protection practices, and operational risk. Third-party arrangements include contractual obligations to maintain compliance with applicable AML/CFT standards. Ongoing monitoring of vendor performance and risk exposure is conducted, with corrective actions taken as needed.

11. Definitions

For purposes of this policy, the following terms have the indicated meanings:

  • Anti-Money Laundering (AML): A set of processes designed to detect, deter, and report money laundering activities.
  • Counter-Terrorist Financing (CFT): Measures to prevent financing of terrorist activities.
  • Know Your Customer (KYC): Procedures to verify identity and understand customer risk profiles.
  • Suspicious Activity Report (SAR): A confidential report filed with the appropriate authorities when suspicious activity is detected.
  • High-Risk Customer: A customer whose geography, behavior, or source of funds signals elevated AML risk.
  • Enhanced Due Diligence (EDD): Additional measures for high-risk customers, including source of funds verification and biometric checks.
  • Politically Exposed Person (PEP): An individual in a prominent public role or associated close family/contacts, who may pose greater AML risk.
  • Transaction Monitoring: Ongoing surveillance of customer transactions to detect illicit activity.
  • Sanctions: Legal restrictions or penalties imposed by authorities to prevent transactions with targeted individuals or entities.