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Aml & Kyc Policy

1. Purpose and Scope

JILIDREAM adopts this AML and KYC Policy to prevent money laundering, the financing of terrorism, and related financial crime across all jurisdictions in which we operate. The Policy applies to all customers, prospective customers, employees, contractors, and any entity acting on behalf of JILIDREAM, and governs onboarding, account management, and all monetary transactions conducted through our platform.

2. Governance and Compliance Structure

The Company designates an AML Compliance Person responsible for administering the program, reporting to senior management, and coordinating ongoing risk assessment, monitoring, and reporting. The AML Compliance Person shall maintain written procedures, supervise staff training, and ensure timely cooperation with competent authorities. All controls shall be reviewed at least annually or whenever changes in law or risk arise.

3. Customer Identification and KYC Onboarding

On registration, JILIDREAM will establish the identity of each applicant using a risk‑based approach and collect minimum identifying information. The Company will not open anonymous accounts or accounts under fictitious names. Required information includes: a) date of birth establishing eligibility (over eighteen); b) full name; c) current residential address; d) contact email; e) payment method ownership details; and f) chosen username and password.

  • The Company may supplement information with documentary evidence or third‑party checks as permitted by applicable data protection rules.
  • Documents to verify identity and address may include a government‑issued ID or passport and a recent proof of address. Verification should be completed prior to processing payments exceeding EUR 1,000 per single event or cumulative across a defined period if risk is identified.
  • Where the risk warrants, the Company may request additional documents or employ independent verification against public records or trusted reference data.

4. Enhanced Due Diligence and Risk-Based Approach

JILIDREAM applies enhanced due diligence for higher‑risk profiles, including politically exposed persons, complex ownership structures, non-resident accounts, or transactions involving unusual patterns. The AML Compliance Person will determine the level of scrutiny, implement additional verification steps, and monitor such accounts more intensively.

5. Ongoing Monitoring and Transaction Review

All accounts are subject to continuous monitoring. The Company reviews the background and purpose of complex or large transactions and any activity likely to be linked to money laundering or terrorist financing. Monitoring is achieved through automated systems and periodic manual review by the AML Compliance Person.

  • Thresholds: transactions equal to or exceeding EUR 1,000 in a single occurrence or aggregated within a defined period trigger enhanced review and documentation of the underlying source of funds and purpose.
  • Reporting: the AML Compliance Person maintains records of monitoring results and escalates suspicious activity in accordance with internal procedures and applicable law.
  • Source of funds: the Company may request supporting documentation for large or unusual deposits, including bank statements or financial statements, as permitted by data protection laws.

6. Cash Handling and Payment Flows

JILIDREAM does not accept cash payments. Accepted funding methods include credit/debit cards, electronic transfers, bank wires, and other payment methods approved by the applicable regulators. Funds may only be received via the methods described and must originate from accounts owned or controlled by the payer.

Funds from winnings or refunds will generally be returned using the same method channel that collected the funds, where practicable. Inter‑user transfers between player accounts are prohibited unless explicitly authorized by applicable regulation. If third‑party processors are used, they must provide transaction monitoring capabilities and be subject to the Company’s monitoring and audit requirements.

7. Third-Party Processors and Vendor Controls

When JILIDREAM engages third‑party processors for payments, the Company will ensure that these providers maintain adequate transaction monitoring, anti‑money‑laundering controls, and data protection measures. The AML Compliance Person shall review service agreements to confirm the adequacy of compliance obligations and the right to audit or request information as needed.

8. Records and Data Protection

All identifying information, transactional data, and verification documents shall be maintained in secure form and retained in accordance with the data protection laws of the jurisdiction in which JILIDREAM operates and any other applicable law. Records of financial transactions shall be kept for a minimum period of five (5) years from the date of the last activity, or longer if required by law, and shall be accessible to the AML Compliance Person for monitoring and regulatory reporting purposes.

9. Suspicious Activity Reporting

The AML Compliance Person shall investigate and, where warranted, report to the relevant authorities any activity indicating potential money laundering or terrorist financing. Reportable indicators include, but are not limited to:

  • Sanctions or terrorist‑related lists associated with the customer or counterparties;
  • Funds derived from illicit activity or used to conceal illicit assets;
  • Transactions with no apparent lawful purpose or inconsistent with the customer’s profile;
  • Structuring or other attempts to evade reporting thresholds or monitoring systems.

Where a report is deemed appropriate, the AML Compliance Person will document the rationale, preserve evidence, and coordinate with regulatory authorities as required by law. The Company may, at its discretion, temporarily freeze an account pending investigation or regulatory notification.

10. Training and Awareness

JILIDREAM provides ongoing AML training to all staff, led by the AML Compliance Person and senior management. Training occurs at least annually and covers identification of suspicious activity, data handling, escalation procedures, and regulatory requirements relevant to the Company’s operations. Training materials are updated to reflect changes in law and evolving risk scenarios.

11. Roles and Responsibilities

  • AML Compliance Person: administers the program, conducts risk assessments, performs monitoring reviews, and leads reporting to authorities.
  • Senior Management: ensures proper resourcing, approves policy updates, and oversees compliance culture.
  • Operations and Customer Support: collect information, verify identities, and respond to verification requests in a timely manner.
  • Internal Audit: periodically reviews adherence to the AML and KYC Policy and tests controls.

12. Compliance with Law and Cooperation

JILIDREAM complies with applicable AML/CFT laws and regulatory guidance in the jurisdictions where we operate. The Company will cooperate with authorities, provide information requested for investigations, and implement administrative or operational changes to meet regulatory requirements.

13. Policy Review and Amendments

This Policy is subject to annual review and may be updated in response to regulatory changes, new risk indicators, or business evolution. All material changes require approval by the appropriate governance body and will be communicated to staff in a timely manner.

14. Contact Information

For questions regarding this Policy or to report concerns, contact the JILIDREAM AML Compliance team at aml at jilidream dot com. Communications about potential suspicious activity should be directed through the same channel in accordance with internal procedures.

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