Aml

AML Policy and Compliance Framework

Dada8 operates online gaming and betting services under a licensing regime that requires robust measures to preventMoney Laundering and the financing of terrorism. This policy applies to all products, services, players, and personnel associated with Dada8, and establishes the controls, governance, and reporting obligations necessary to comply with applicable AML/CFT laws, directives, and regulatory conditions in the jurisdictions in which Dada8 operates.

Objectives

The objective is to identify, assess, and mitigate money laundering and terrorist financing risks; to ensure the integrity of the gaming platform; and to satisfy licensing requirements and corresponding regulatory reporting duties. Dada8 will regularly review and update this policy in response to evolving law and risk factors.

Definitions and Scope

For purposes of this policy, the following terms shall have the meanings set out below: (i) Player means any natural person accessing or attempting to access Dada8 gaming or betting services; (ii) Know Your Customer (KYC) refers to the processes used to verify identity and assess risk; (iii) Enhanced Due Diligence (EDD) denotes heightened verification and monitoring for elevated-risk scenarios; (iv) Transactions include deposits, withdrawals, and transfers initiated through Dada8.

Customer Identification and Verification (KYC)

  • Data collection: at account registration, Dada8 shall collect minimum data including date of birth, full name, residential address, valid email, payment method details, username, and password.
  • Identity verification: the holder’s identity shall be verified by presentation of an official government-issued document (e.g., passport or national ID) and, where required, a proof of address document. Verification may be supplemented by third-party data sources compliant with applicable law.
  • Account opening restrictions: anonymous or fictitious accounts are prohibited. Where uncertainty exists, verification shall be completed before permitting significant activity.
  • Sanctions and PEP checks: all players shall be screened against sanctions and politically exposed person lists. If a match is confirmed, the corresponding account shall be frozen pending further investigation.

Ongoing Transaction Monitoring and Due Diligence

Dada8 conducts continuous transaction monitoring on a risk-based basis. The following controls apply:

  • Automatic monitoring of activity with daily reporting for transactions above EUR 1,000, including related identifiers and context;
  • Per-player summaries of documentation collected and any changes thereto, maintained for auditability;
  • The AML Compliance Officer oversees ongoing monitoring, initiates additional verification steps where needed, and determines escalation to regulatory authorities where appropriate.

Suspicious Transactions and Reporting

The AML Compliance Officer shall report, in accordance with applicable law, any suspicious activity involving EUR 1,000 or more (per transaction or aggregated across a player’s activity) where there are reasonable grounds to suspect money laundering or terrorist financing. Grounds for reporting include, but are not limited to: involvement of illicit proceeds, structuring, use of Dada8 to facilitate criminal activity, or transactions lacking a plausible lawful purpose. Reports shall be made to the relevant authorities within legally mandated timeframes.

Payment Methods and Fund Handling

  • Allowed payment methods: electronic cards, electronic transfers, bank wires, e-wallets, and any other methods approved by the applicable regulator. Dada8 shall not accept cash.
  • Return of funds: winnings or refunds shall be returned via the same method used to originate the funds where practicable.
  • Inter-user transfers: transfers between Player accounts are prohibited.

Record Keeping and Data Retention

All records relating to customer identities, verification documents, transaction data, and monitoring results shall be retained in compliance with applicable data protection and retention laws. Retention periods shall be the longer of the regulatory minimum or as required by licensing conditions, and data shall be stored securely with access restricted to authorized personnel.

Training and Awareness

Dada8 shall provide ongoing AML training to relevant staff, with a formal program conducted at least annually. Training content reflects current laws, regulatory expectations, and internal procedures, and training records shall be maintained for audit purposes.

Governance, Oversight, and Compliance Roles

The AML Compliance Officer leads the program, including policy implementation, monitoring, escalation, and reporting to authorities. The role has authority to freeze or restrict accounts, request additional information, and coordinate with regulators. A designated deputy and escalation paths are established to ensure continuity of oversight.

Data Protection and Privacy

All processing of personal data under this policy complies with applicable data protection laws. Personal data shall be processed lawfully, accurately, and securely, with access limited to authorized personnel. Cross-border data transfers shall be conducted subject to appropriate safeguards in line with regulatory requirements.

Contact and Escalation

Players and employees may raise AML concerns through the designated AML contact channel published in the account area and terms and conditions. Dada8 will respond in accordance with applicable law and internal procedures, preserving confidentiality and protecting the rights of individuals during the investigation process.