WinWin KYC & AML Policy
KYC (Know Your Customer) and AML (Anti-Money Laundering) procedures on WinWin set out how the platform identifies each account holder, assesses financial risk and responds to suspicious activity in Bangladesh. These procedures support compliance with local regulatory requirements on anti-money laundering and counter-terrorism financing and help protect user safety, account protection and fair play.
Purpose of KYC & AML
KYC and AML controls are applied to every account to verify identity, support ID verification and identity check processes, prevent fraud and misuse, and reduce the risk of financial crime. These controls help maintain transparency in gaming and betting services provided to users in Bangladesh.
The KYC and AML framework aims to provide:
- Fair play and equal treatment for all registered users
- User safety through structured security measures and account protection
- Transparency on how personal data and document submission are used for compliance
- Adherence to regulatory requirements on anti-money laundering and counter-terrorism financing
- Responsible gaming supported by monitoring of deposits, withdrawals and betting patterns
KYC Requirements
Every new user must complete identity verification as part of the registration and account activation process. ID verification and identity check procedures may be repeated at any time where risk-based assessments, transaction monitoring or regulatory obligations require updated information.
The platform may request the following document categories during KYC document submission:
- Government-issued photo identification (such as national ID card, passport or driving licence)
- Proof of address confirming current residential information (such as utility bills or official bank statements)
- Confirmation of ownership and control of payment methods used for deposits and withdrawals
- Additional documents or information required to clarify source of funds or source of wealth in higher-risk cases
AML Measures and Security Measures
The platform applies structured AML controls and security measures to limit the risk of money laundering, terrorism financing and other illegal activity. These measures support ongoing transaction monitoring, timely identification of suspicious activity and compliance with reporting obligations in Bangladesh.
Core AML and counter-terrorism financing controls include:
- Continuous transaction monitoring of deposits, withdrawals and betting behaviour for unusual or inconsistent patterns
- Automated detection rules designed to flag potential account misuse or financial crime indicators
- Enhanced due diligence for high-risk events, users or payment methods based on risk assessment
- Detailed review of large, irregular, complex or cross-border transfers or bets that do not align with known customer profiles
- Risk scoring for accounts to determine the level of scrutiny, documentation and review required
- Screening against international sanctions lists and identification of politically exposed persons (PEPs) where applicable
- Internal escalation and reporting to competent authorities when suspicious activity meets legal reporting thresholds
- Regular review and improvement of AML procedures to align with updated regulatory requirements in Bangladesh
Prohibited Activities Supporting AML and KYC
Certain activities are strictly forbidden in order to maintain effective KYC and AML compliance and to protect user safety and fair play on the platform. Any attempt to bypass identity check procedures, document submission rules or transaction monitoring may lead to enforcement measures.
Prohibited activities include:
- Opening or using multiple accounts by the same individual in order to conceal identity, source of funds or betting history
- Use of forged, altered, stolen or otherwise invalid identification documents or proof of address
- Any attempt to use the platform for money laundering, terrorism financing or other financial crime
- Manipulation of systems, odds, games or transaction flows to disguise the origin of funds or winnings
- Sharing, selling or otherwise allowing third parties to access or control a registered gaming or betting account
- Using payment instruments, bank accounts or e-wallets that belong to third parties or are not legally controlled by the account holder
- Misrepresentation of identity, employment status, source of funds or other material information during registration or ongoing verification
Consequences of Non-Compliance
Violations of KYC and AML rules, refusal to cooperate in ID verification or identity check processes, or any suspicious activity linked to an account may lead to disciplinary and legal consequences. These measures are applied in line with internal policies and relevant laws in Bangladesh.
Possible measures in case of non-compliance include temporary or permanent account suspension, freezing or confiscation of funds linked to suspicious activity, cancellation of bets or winnings, reporting to competent authorities where applicable.
User Responsibilities in KYC and AML Compliance
Every account holder is responsible for providing accurate, complete and up-to-date personal data during registration and throughout the use of the platform. Users must complete all requested ID verification and document submission steps within the time frames communicated by the compliance team. Timely responses to any additional requests for documents or clarification support effective transaction monitoring and help demonstrate the lawful origin of funds.
Users are required to use only those payment methods that are registered in their own name and under their control, and must not allow others to deposit, bet or withdraw through their personal account. Any suspected misuse of an account, unauthorised access, or suspicious activity relating to deposits, withdrawals or betting should be reported to customer support without delay. Cooperation with these obligations supports account protection, user safety, responsible gaming and adherence to Bangladeshi regulatory requirements.
Fair Play and Transparency Commitments
The platform upholds fair play and transparency in all gaming and betting activities to maintain a safe environment for users in Bangladesh. AML, KYC and responsible gaming policies are applied consistently to preserve integrity and to support trust in the platform.
Key principles of fair play and transparency include:
- Full alignment of identity check, KYC and AML processes with applicable regulatory requirements
- Protection of personal data, financial information and submitted documents through appropriate security measures
- Ongoing monitoring for suspicious activity and prompt escalation of concerns for internal review
- Prevention of manipulation, collusion and any other behaviour that may undermine fair play
- Availability of user support to address safety, account protection and responsible gaming questions
- Recognition that safety and compliance are shared responsibilities between the platform and each account holder
- Application of rules, limits and controls on an equal basis to all users, without unfair advantage or discrimination
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