CasinoWithMe is operated by TYYA Global N.V., a company registered in the Autonomous Island of Anjouan, Union of Comoros and licensed by the Anjouan Offshore Finance Authority.

CasinoWithMe is committed to the prevention of money laundering and the financing of terrorism. This Anti-Money Laundering (AML) Policy outlines our approach to ensure compliance with applicable laws, including the EU’s Sixth Anti-Money Laundering Directive (6AMLD), the FATF Recommendations, and the General Data Protection Regulation (GDPR).

To safeguard our platform, our users, and the financial system, CasinoWithMe has implemented a three-step account verification process and continuous transaction monitoring. Our objective is to ensure that user identities are verified, that financial activity through the Wallet is legitimate, and that risks related to money laundering and terrorism financing are mitigated.

CasinoWithMe aligns its AML measures with:

• Directive (EU) 2015/849, as amended by Directive (EU) 2018/843 and Directive (EU) 2018/1673 (6AMLD)
• GDPR (Regulation (EU) 2016/679)
• The AML legislation of the Union of Comoros and the Autonomous Island of Anjouan, and the conditions of our licence issued by the Anjouan Offshore Finance Authority
• Relevant FATF Recommendations

Money laundering involves:

• Concealing the origin of criminal proceeds
• Converting or transferring illicit assets to disguise their origin
• Acquiring or using criminally obtained property knowingly
• Aiding or facilitating any of the above actions

Terrorism financing is the provision or collection of funds, from any source, with the intention or knowledge that they will be used to support terrorist acts or organizations, whether or not the funds are of criminal origin.

Money laundering is illegal even when the predicate offence occurs in another jurisdiction.

• The senior management of TYYA Global N.V. holds ultimate responsibility for AML compliance.
• A Money Laundering Reporting Officer (MLRO) oversees implementation, reporting, and risk assessments.
• An independent, qualified third party reviews this Policy at least annually.

CasinoWithMe enforces identity verification before a user’s first deposit to the Wallet, during certain transactions, and whenever the risk presented by an account requires it, in order to comply with applicable AML/CFT regulations. The same process applies to every user, whether they play, publish content, or both, because all funds are withdrawn from the Wallet. To facilitate this process, CasinoWithMe uses Ondato as its third-party identity verification provider. All personal information submitted during the verification process is processed securely and in accordance with applicable data protection laws and our Privacy Policy.

Required documents, all collected and checked through Ondato:

• Passport, with all corners of the document visible and only the essential fields (name, date of birth, nationality, document number, and photo) processed unless further data is necessary, and a live selfie matched against it.
• Proof of address, where the risk of the account requires it: a utility bill, government letter, or bank statement dated within the last three (3) months.
• Source of funds, where the risk of the account requires it: employment documents, proof of business ownership, inheritance, or investment records.

CasinoWithMe conducts Politically Exposed Person (PEP) and adverse media screening as part of its customer due diligence procedures through third-party compliance service providers, including Ondato. Screening is performed on a risk-based basis during verification and may be repeated periodically throughout the customer relationship to identify potential money laundering, corruption, fraud, sanctions exposure, or other financial crime risks.

CasinoWithMe applies Enhanced Due Diligence (EDD) measures to users deemed higher risk due to factors including, but not limited to, jurisdiction, transaction behaviour, source of funds, source of wealth, PEP status, adverse media findings, sanctions exposure, unusual transaction activity, or other risk indicators. EDD measures, conducted with the assistance of third-party compliance service providers, including Ondato, may include obtaining additional identity verification documents, source of funds and source of wealth information, enhanced transaction monitoring, manual compliance reviews, and temporary account or withdrawal restrictions pending completion of the review.

All deposits, wagers, payments between users, and withdrawals pass through the Wallet. CasinoWithMe employs a three-tiered transaction monitoring system:

1. Automated monitoring. Rule-based systems detect irregularities such as repeated deposits and withdrawals without gameplay, deposits from many different wallet addresses, structuring of transactions below review thresholds, and changes in account behaviour, location, or device.
2. Employee review. Trained personnel review the alerts, request further information from the user where needed, and perform manual verification.
3. Manual audits. Higher-risk users and suspicious accounts are audited manually.

All suspicious transactions are escalated to the MLRO.

CasinoWithMe screens users and transactions against applicable international sanctions and watch lists, including but not limited to those of the United Nations (UN), the Office of Foreign Assets Control (OFAC), and the European Union (EU), using third-party compliance service providers, including Ondato. Screening is performed on a risk-based basis during verification, during certain transactions, and periodically throughout the customer relationship. Users identified as sanctioned persons or entities may be restricted, suspended, rejected, or reported to the relevant authorities in accordance with applicable laws and regulations.

Because all deposits and withdrawals are made in cryptocurrency, CasinoWithMe monitors the wallet addresses involved and may use blockchain analytics tools to identify high-risk wallet addresses, sanctioned entities, suspicious transaction patterns, exposure to illicit activities, and other indicators of financial crime. CasinoWithMe reserves the right to request additional information, apply enhanced due diligence, suspend transactions, or restrict account activity where concerns are identified.

CasinoWithMe conducts an annual Enterprise-Wide Risk Assessment (EWRA), analysing:

• Products and services offered
• Transaction types and the cryptocurrencies accepted
• User profiles and geographies
• Delivery channels and emerging risks

The MLRO uses the outcome of the assessment to adjust this Policy and the monitoring thresholds.

All employees must report suspicious activity to the MLRO. The MLRO:

• Reviews the report
• Files a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit (FIU) if necessary
• May restrict, suspend, or terminate user accounts based on the findings

Users are not informed that a report has been or may be made about them.

In line with legal requirements:

• KYC documentation is retained for five (5) years after account closure.
• Transaction records are stored securely and retained for five (5) years.
• Records of alerts, reviews, and reports are retained for the same period.

• All employees with access to user accounts or transactions undergo mandatory AML training annually.
• New hires receive AML instruction tailored to their role.
• Training is updated in line with regulatory changes.

CasinoWithMe complies with the GDPR. User data:

• Is securely stored
• Is not shared unless legally required (e.g., AML investigations)

See our Privacy Policy for details.

For AML or KYC-related inquiries: support@casinowithme.com. Complaints are handled under our Complaints policy.

Version: 1.0

Last reviewed: 20 October 2026

Next scheduled review: September 2027