Introduction
The Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy governs Dada8's compliance program for all customers and transactions conducted on the platform. It sets mandatory requirements for identification, verification, ongoing monitoring, reporting, and record-keeping in alignment with applicable laws and regulatory expectations.
Legal Framework and Supervisory Oversight
Dada8 operates under the relevant AML/CFT laws and is subject to supervision by the competent supervisory authority. The Company applies a risk-based approach to compliance and revises procedures to reflect changes in law, technology, and regulatory guidance.
Scope of Application
This policy applies to all customer onboarding activities, account management, deposits, wagering, winnings, transfers, and withdrawals on the Dada8 platform, including interactions with payment processors and service providers acting on behalf of Dada8.
KYC and Identity Verification (Onboarding)
- Identity Documentation: All customers must provide valid government-issued identification (e.g., passport or national ID) and proof of address (e.g., utility bill, bank statement).
- Verification Window: Upon registration, customers have 30 days to complete the verification process. Failure to verify within 30 days results in account restrictions until verification is completed.
- Account Ownership: Accounts must be registered in the individual's name. Transfers or sharing of accounts are prohibited and may result in account lockout and withholding of funds.
- Prohibition on Early Activity: Gambling activity and withdrawals are not permitted until verification is completed.
- Information Sources: Verification may include public records and third-party verification to confirm identity and residence.
Account Access, Deposits, and Withdrawals
Withdrawals are available only to verified accounts. Unverified accounts may be restricted from withdrawals and certain features until verification is completed in accordance with this policy and applicable law.
Due Diligence Framework: SDD, CDD, and EDD
Dada8 applies a risk-based approach to customer due diligence (CDD). Depending on risk factors, customer type, and behavior, we implement one or more of the following levels of due diligence:
- Simplified Due Diligence (SDD): Applied for extremely low-risk scenarios with minimal data collection beyond basic verification.
- Customer Due Diligence (CDD): Standard verification for typical customer profiles and activities.
- Enhanced Due Diligence (EDD): Applied for high-risk customers, large or unusual transactions, or special cases; may include additional data collection, site verification, or third-party checks.
Ongoing Monitoring and Transaction Screening
Dada8 conducts ongoing monitoring of customer accounts and transactions to identify suspicious activity and assess risk. We review for unusual or large transactions and patterns consistent with money laundering or financing of terrorism. In particular, we monitor and assess transactions that exceed 10,000 USD within any 24-hour period for potential escalation and review.
Reporting Suspicious Activity
We comply with all applicable reporting obligations concerning suspicious activities or transactions. Any indicators of potential illicit activity are promptly reported to the relevant regulatory authorities in accordance with law and internal escalation procedures.
Record Keeping
Dada8 maintains all customer identification data, verification documentation, and transaction records for the period required by law. Records are stored securely with audit-ready accessibility for internal reviews and regulatory examinations.
Compliance Leadership
A designated Compliance Officer oversees the implementation and ongoing enforcement of AML/KYC policies, coordinates internal reporting, and ensures staff adherence to regulatory requirements.
Employee Training
All personnel receive regular AML/KYC training, including identification of red flags, due diligence procedures, escalation protocols, and changes in regulatory expectations. Training records are maintained and reviewed for effectiveness.
Third-Party Obligations
All third-party service providers engaged by Dada8 must comply with our AML/KYC requirements and provide information and reports as required by law and contract. We perform due diligence on third parties and monitor ongoing compliance through contractual obligations and audits as appropriate.
Review, Update, and Governance
The AML/KYC policy is reviewed at least annually and updated as needed to reflect regulatory changes, risk developments, and business evolution. Updates are approved by the Compliance Officer and communicated to relevant stakeholders.
Data Privacy and Scope of Data Collection
Data collection under this policy is limited to information necessary to establish identity, assess risk, and fulfill regulatory obligations. Personal data is processed in accordance with Dada8's privacy policy and applicable data protection laws, with access restricted to authorized personnel.