Anti-Money Laundering and Customer Verification Policy

1. Policy Objective

Mobile Incorporated Limited (the "Company", "we", "our", or "us") is committed to maintaining effective controls to prevent its products and services from being used for money laundering, terrorist financing, fraud, or other forms of financial crime.

As the holder of a Business-to-Consumer Gaming Service Licence issued by the Malta Gaming Authority ("MGA"), the Company complies with all applicable Maltese Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") legislation and applies a risk-based approach to customer due diligence and ongoing monitoring.

This Policy applies to every customer who registers or maintains an account with the Company.

2. AML and KYC Framework

The Company has established internal policies, procedures, and controls designed to:

  • identify and verify customers;
  • understand the nature and purpose of customer relationships;
  • assess and manage financial crime risks;
  • monitor customer activity throughout the business relationship;
  • detect and report suspicious activity; and
  • comply with all applicable legal and regulatory obligations.

The level of verification applied to a customer will depend upon the risk associated with that customer and the nature of the transactions undertaken.

3. Customer Identification

Before permitting certain account activities, and whenever required throughout the customer relationship, the Company may require customers to complete identity verification.

Verification may include confirmation of:

  • full legal name;
  • residential address;
  • date of birth;
  • nationality;
  • ownership of payment methods used; and
  • any additional information necessary to satisfy regulatory requirements.

Identity verification may be performed through electronic verification providers, documentary evidence, or a combination of both.

Where satisfactory verification cannot be obtained, the Company reserves the right to refuse account registration, suspend account functionality, restrict transactions, or terminate the business relationship.

4. Enhanced Customer Due Diligence

Additional due diligence measures may be applied where the Company considers that higher levels of AML or CTF risk exist.

Enhanced verification may be required where:

  • a customer is identified as a Politically Exposed Person (PEP);
  • sanctions screening identifies a potential match;
  • transaction values or customer behaviour present increased risk;
  • source of funds or source of wealth cannot be readily established;
  • the customer has links to higher-risk jurisdictions; or
  • unusual or complex transactions are identified.

Enhanced Due Diligence may include requests for additional identification documents, financial records, independent verification, or approval by senior compliance personnel before account activity may continue.

5. Source of Funds and Source of Wealth

To satisfy regulatory obligations, the Company may request evidence demonstrating the lawful origin of funds used on the platform and, where appropriate, the customer's overall source of wealth.

Supporting documentation may include, among other things:

  • recent bank statements;
  • salary slips or employment confirmation;
  • tax documentation;
  • company ownership records;
  • inheritance documentation;
  • investment records; or
  • contracts relating to the sale of assets.

Failure to provide satisfactory evidence may result in restrictions being placed on the account until the review has been completed.

6. Ongoing Transaction Monitoring

Customer activity is monitored throughout the duration of the business relationship using automated systems together with manual compliance reviews.

Monitoring is intended to identify activity including, but not limited to:

  • unusual deposit or withdrawal patterns;
  • rapid movement of funds with limited gaming activity;
  • inconsistent betting behaviour;
  • structuring designed to avoid reporting thresholds;
  • transactions inconsistent with known customer information; and
  • any activity that may indicate financial crime.

Where necessary, additional due diligence may be undertaken before further account activity is permitted.

7. Withdrawal Controls and Verification Requirements

The Company may apply verification requirements before processing withdrawals where necessary to comply with AML, CTF, fraud prevention, or regulatory obligations.

Identity verification may be required where a customer's cumulative deposits exceed €2,000.

For this purpose, cumulative deposits may be calculated either:

  • on a cumulative daily basis, taking into account all deposits made by the customer since the commencement of the business relationship; or
  • over a rolling period of one hundred and eighty (180) days.

Where enhanced verification becomes necessary, withdrawal requests may remain pending until the required documentation has been received, reviewed, and approved.

The Company may also request further documentation relating to the customer's identity, payment methods, source of funds, or any other information considered necessary to satisfy regulatory requirements before withdrawals are authorised.

8. Sanctions and Politically Exposed Person Screening

The Company performs sanctions and PEP screening as part of its onboarding process and throughout the customer relationship.

Customers may be screened against:

  • European Union sanctions lists;
  • United Nations sanctions lists;
  • national sanctions registers;
  • Politically Exposed Person databases; and
  • other relevant watchlists considered appropriate by the Company.

Potential matches are reviewed by Compliance before any decision is made regarding the customer relationship.

9. Suspicious Activity Reporting

Where the Company knows, suspects, or has reasonable grounds to suspect that funds are connected with money laundering, terrorist financing, or other criminal conduct, it will comply with its legal reporting obligations by submitting a Suspicious Activity Report ("SAR") to the Financial Intelligence Analysis Unit ("FIAU").

The Company is prohibited by law from informing a customer that a report has been submitted or that an investigation is being conducted.

The Company will cooperate fully with the FIAU, the Malta Gaming Authority, and any competent law enforcement authority.

10. Customer Responsibilities

Customers are expected to:

  • provide complete and accurate information when registering an account;
  • ensure personal information remains current;
  • respond promptly to requests for verification;
  • provide genuine and unaltered documentation when requested; and
  • cooperate with any compliance review undertaken by the Company.

Failure to comply with these requirements may result in restrictions on the account, suspension of services, refusal of transactions, or closure of the account.

11. Governance and Compliance Oversight

The Company's AML framework is supported through appropriate governance arrangements, including:

  • appointment of a Money Laundering Reporting Officer (MLRO);
  • documented AML and CTF procedures;
  • internal reporting and escalation mechanisms;
  • periodic financial crime risk assessments;
  • independent compliance monitoring; and
  • regular employee training on AML and CTF obligations.

The effectiveness of these controls is reviewed periodically to ensure continued compliance with legal and regulatory requirements.

12. Record Retention and Information Security

The Company maintains records relating to customer identification, verification, risk assessments, transactions, monitoring activities, and regulatory reporting in accordance with applicable Maltese legislation.

Records are retained for a minimum period of five (5) years following the end of the business relationship or from the date of the last transaction, as applicable.

Information collected under this Policy is processed securely and confidentially in accordance with the Company's data protection obligations, including the General Data Protection Regulation (GDPR). Access to such information is restricted to authorised personnel and competent authorities where disclosure is required by law.

13. Policy Review

This Policy is reviewed periodically to ensure continued compliance with legal, regulatory, and operational requirements.

The Company reserves the right to amend this Policy at any time where necessary to reflect changes to applicable legislation, regulatory guidance, business operations, or risk management practices. Updated versions will be made available through the Company's official channels.