Purpose and Scope

This Know Your Customer (KYC) Policy governs identity verification, anti money laundering (AML) and counter‑terrorist financing (CTF) controls, ongoing customer due diligence, and related data handling for all users of the Jkjili platform. It prescribes onboarding requirements, activities subject to verification, and the actions the company may take where information is incomplete, investigated, or non‑compliant, in accordance with applicable laws and licensing obligations.

Definitions

  1. KYC: processes to establish customer identity, assess risk, and enable ongoing monitoring of activity in relation to the user’s profile and transactional behavior.
  2. AML/CTF: measures designed to detect and prevent money laundering, the financing of crime, and related illicit activity, including reporting to authorities where required.
  3. PEP: a politically exposed person or a close associate or family member of such a person, as defined by applicable law, requiring enhanced due diligence.
  4. Source of Funds (SOF) and Source of Wealth (SOW): the origin of funds used for transactions and the customer’s overall wealth, respectively.
  5. Ongoing Monitoring: continuous review of account activity to identify transactions that are inconsistent with the customer’s profile or risk tier.
  6. Suspicious Activity: any transaction or pattern of activity that may indicate money laundering, fraud, or other illicit conduct and which may require reporting to authorities.

Onboarding and Identity Verification

Jkjili will collect and verify information before permitting certain monetary actions. Verification may be conducted at registration and revisited as part of ongoing monitoring or when triggered by risk indicators.

  1. Minimum data to collect at registration: full legal name, date of birth, citizenship, permanent residence address, a means of contact (email or phone), and a valid form of identity.
  2. Verification steps: identity verification using government‑issued documents, corroboration of address, and cross‑ checks with third‑party data sources as permitted by law. Where required, additional documentation may be requested to complete verification.
  3. Withdrawal and activity restrictions: until verification is complete, withdrawals may be restricted and new deposits may be limited as determined by risk assessment.
  4. Consequences of inaccurate information: provision of false, misleading, or incomplete information may result in immediate restriction, suspension, or termination of the account and services, in addition to other remedies available under law and the Terms and Conditions.
  5. Age verification: if it is determined that the user is below the legal age, the account will be suspended or closed and any ongoing activity halted in accordance with applicable law and regulatory obligations.

Minimum Identity Data Set

  • Full legal name and date of birth;
  • Nationality and country of residence;
  • Permanent address (street, city, postal code, country);
  • One form of government‑issued identity number or document number;

Required and Additional Documentation

Customers may be required to provide documents to confirm identity and residence. Documentation may be requested for enhanced due diligence or as part of ongoing monitoring.

  • valid passport, national identity card, or other government‑issued travel document.
  • recent (within the last 3 months) utility bill, bank statement, government letter, or official document indicating the customer’s name and address.
  • Additional documents (as applicable): national identity card with a photograph; reverse‑side documents for identity cards or licenses; a photo of the cardholder with the document clearly readable; a payment card’s front with the cardholder name and expiry date visible, and partial digits disclosed in accordance with payment provider policies.

Where necessary, the customer may be asked to provide evidence of the source of funds or source of wealth, including but not limited to:

  • Recent payslips, salary statements, or management fees;
  • Bank statements or savings accounts showing consistent, verifiable funds;
  • Evidence of ownership or control of funds (for example, beneficiary statements, investment certificates);
  • Documented receipts of rewards or payments to the customer with dating information.

Documents must be legible and match the information supplied by the customer. The following will not be accepted: clearly mismatched address or account name, unreadable or duplicated documents, or copies that obscure essential details. Refusal or non‑acceptance of documents may delay or prevent service access.

Risk‑Based Approach and Ongoing Monitoring

Jkjili applies a risk‑based framework to KYC, AML, and CTF compliance. The level of due diligence and monitoring increases with the assessed risk of the customer and the nature of activities. The company retains the right to escalate verification, request additional documents, lock or restrict accounts, and suspend services pending completion of verification or investigation.

Anonynity Prohibition, and Multiple Accounts

Anonymous accounts or accounts lacking verifiable identity are not permitted. Where identity cannot be established, the account may be closed and related funds returned to the funding source or otherwise reconciled in accordance with applicable policies and law. The company may identify and link related or multiple accounts and treat them as a single customer; in such cases, additional account closures or the suppression of winnings and/or refunds of deposits may follow in the company’s discretion.

Politically Exposed Persons (PEP) and High‑Risk Clients

Customers who are identified as PEPs or linked to high‑risk profiles will be subjected to enhanced due diligence. Risk scoring, additional verification, ongoing monitoring, and potential limits on activity or enhanced reporting may apply based on the level of risk and in compliance with applicable law.

Use of Information and Sharing

Data collected under this policy may be used to verify identity, assess risk, and monitor activity. Information may be shared with regulatory authorities, financial institutions, payment service providers, and other entities as required or permitted by law to achieve compliance, detect illicit activity, or protect the integrity of the platform. Any sharing will occur in accordance with data protection and privacy requirements and only to the extent necessary for the purposes described in this policy.

Suspicious Activity and Reporting

Any staff member who knows, suspects, or has reasonable grounds to suspect that a money laundering offence or related illicit activity is occurring must report it to the appropriate internal compliance function and, where required, to the competent authorities. The company will not disclose the existence of a SAR (Suspicious Activity Report) or its status to the customer except as permitted by law.

Data Protection, Retention, and Customer Rights

Jkjili acts as the data controller for user data collected in connection with this policy. Personal data will be processed only to the extent necessary for KYC, AML/CTF compliance, customer service, and platform operation. Data will be retained for a minimum of eight (8) years after the end of the user relationship or as required by applicable law and regulatory obligations. Customers have rights to access, rectify, or erase their personal data, withdraw consent where applicable, and request data portability where feasible. Requests should be directed to the designated compliance contact below. Data transfers will be secured and performed in accordance with applicable data protection laws and contractual arrangements with service providers.

Impact on Services and Compliance

Non‑compliance with this policy, including failure to provide required information or documentation, may result in the restriction, suspension, or termination of services, rejection of transactions, or permanent closure of the account. The company reserves the right to refuse any service or to suspend processing where such action is necessary to meet legal, regulatory, or safety obligations.

Underage Conduct and Funds

If it is determined that a user engaged in activities while under the legal age, the account will be suspended or closed. All wagers during such period may be void, and any deposits will be returned to the funding source in accordance with payment provider terms. Any winnings accrued during that period may be removed from the account. The user may be required to reimburse or refund such funds as determined by the company and applicable law.

Policy Updates

This policy is subject to change. Any material changes will be communicated to users in a timely manner and will take effect upon notification or as otherwise required by law. Continued use of the Services after changes constitutes acceptance of the updated policy.

Contact and Compliance Inquiries

For questions about this policy or requests related to identity verification, document submission, or data rights, contact the Jkjili Compliance Team at [email protected].