Rainbet.com AML Policy

Last Updated: April 8, 2025

1. Introduction

Rainbet.com is operated by RBGAMING N.V., registered at Hamchako, Mutsamudu, The Autonomous Island of Anjouan, Union of Comoros. Company Registration Number: 16077.

Rainbet.com maintains a firm commitment to combating money laundering and the financing of terrorism. This Anti-Money Laundering Policy sets out the procedures and controls we use to comply with applicable laws and standards, including the EU’s Sixth Anti-Money Laundering Directive (6AMLD), FATF Recommendations, and the General Data Protection Regulation (GDPR).

2. Objective of the Policy

Rainbet.com has introduced a three-step account verification process and continuous transaction monitoring to protect its platform, customers, and financial systems. These measures are designed to confirm user identity, ensure that financial transactions are legitimate, and manage risks associated with money laundering.

3. Legal Framework

Rainbet.com’s AML framework is aligned with the following:

• Directive (EU) 2015/849, as amended by Directive (EU) 2018/843 and Directive (EU) 2018/1673 (6AMLD).
• Regulation (EU) 2015/847 on information accompanying transfers of funds.
• GDPR (Regulation (EU) 2016/679).
• Anjouan AML legislation.
• Relevant FATF Recommendations.

4. Definition of Money Laundering

Money laundering refers to activities such as:

• Disguising the origin of proceeds generated by criminal activity.
• Converting or moving illicit assets to conceal where they came from.
• Knowingly acquiring, holding, or using property obtained through crime.
• Helping, assisting, or facilitating any of these activities.

Money laundering is considered illegal even if the underlying offense was committed outside the jurisdiction in which the laundering activity is identified.

5. Governance Structure

• The General Management of RBGAMING N.V. has ultimate responsibility for AML compliance.
• The Anti-Money Laundering Compliance Officer (AMLCO) supervises AML implementation, reporting procedures, and risk assessments.

6. Customer Due Diligence (KYC)

Rainbet.com requires identity checks when an account is created and when certain transactions take place.

Required Documents:

• Government-issued ID such as a passport, national ID card, or driver’s license, including:
  • A selfie of the user holding the ID and a handwritten note with 6 randomly generated numbers.
  • Clearly visible document corners.
  • Only essential information fields, such as name, date of birth, nationality, gender, and photo, unless additional data is necessary.
• Proof of Address:
  • Address verification is completed electronically through two databases. If this process fails, the user must provide a manual document, such as a utility bill, government-issued letter, or bank statement dated within the previous 3 months.
• Source of Funds:
  • Acceptable evidence may include employment documents, business ownership records, inheritance documents, or investment documentation.

7. Transaction Monitoring

Rainbet.com operates a three-tier transaction monitoring system:

1. Automated Monitoring: AI-driven tools are used to detect irregular activity, including:

• Multiple deposits or withdrawals without corresponding gameplay.
• Use of different payment methods.
• Changes in user account behavior or geographic patterns.

2. Employee Review:

• Trained employees assess AI-generated alerts and carry out manual verification where appropriate.

3. Manual Audits:

• Suspicious accounts and higher-risk users may be reviewed through manual audits.

All suspicious transactions are referred to the AMLCO.

8. Risk-Based Approach (EWRA)

Rainbet.com conducts an Enterprise-Wide Risk Assessment (EWRA) every year. This assessment considers:

• The products and services provided.
• Transaction categories.
• User profiles and geographic factors.
• Delivery channels and emerging risks.

The AMLCO relies on EWRA findings to revise and strengthen AML policies as needed.

9. Reporting Suspicious Activity

Every employee must report suspicious activity to the AML team. The AMLCO:

• Reviews the reported activity.
• Files a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit (FIU), if required.
• May close user accounts depending on the findings.

10. Record Keeping

Consistent with legal obligations:

• KYC documentation is retained for 10 years after an account is closed.
• Transaction data is stored securely, offline and encrypted, for 10 years.

11. Staff Training

Rainbet.com provides that:

• Employees complete required AML training annually.
• New hires receive academic AML instruction relevant to their position.
• Training is revised when regulatory requirements change.

12. Data Protection

Rainbet.com observes GDPR requirements. User data:

• Is kept in secure storage.
• Is not shared except where legally required, including for AML-related investigations.

13. Contact & Complaints

For AML or KYC-related inquiries, contact:

Email: support@rainbet.com

14. Version Control

Version: 1.2

Last Reviewed: April 8, 2025

Next Scheduled Review: April 2026