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YallaBet – Anti-Money Laundering (AML) & Counter-Terrorist Financing (CFT) Policy
Last Updated: December 2025

1. Introduction
Wonderland Ltd., trading as YallaBet, is committed to preventing its services from being used for money laundering, terrorist financing, or any form of illegal financial activity. This AML/CFT Policy outlines the procedures, controls, and internal systems designed to detect, deter, and report suspicious activities.

YallaBet complies with internationally recognized AML standards, including FATF Recommendations, applicable Anjouan gaming regulations, and industry best practices. This Policy applies to all employees, management teams, contractors, affiliates, third-party service providers, and payment partners involved in handling customer interactions or financial transactions.

2. Purpose of the Policy
This Policy establishes a structured approach to identifying, reducing, and managing the risks of money laundering and terrorist financing. It defines the responsibilities of staff, the procedures for customer due diligence, and the mechanisms used to monitor transactions and report suspicious activity. Its aim is to ensure a secure and transparent gambling environment.

3. VERIFICATION
3.1. Customer Identification Requirements
Formal customer identification is essential for ensuring compliance with Anti-Money Laundering (AML) regulations and Know Your Customer (KYC) obligations. YallaBet.com requires customers to complete verification procedures before certain account actions—such as withdrawals, high-value deposits, or unusual transactional patterns—can be processed.

To complete our verification checks, we may request the following:

• A valid government-issued identification document, such as a national identity card, passport, or driver’s license, along with
• A recent proof of address, such as a utility bill, council tax letter, or bank/building society statement dated within the last six (6) months.
• Proof of ownership of the payment method used for deposits, which may include:
  • A copy of the credit/debit card used (with sensitive digits masked),
  • A screenshot of the relevant e-wallet account, or
  • A recent bank statement confirming account ownership.

YallaBet.com may request additional documentation at any time if deemed necessary to complete verification or resolve discrepancies.

3.2. Indicators (“Red Flags”) of Potential Money Laundering
Below are potential indicators that YallaBet.com employees should consider when assessing customer activity for possible money laundering risks:

• Uncooperative customers who refuse or delay completing Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD) requirements.
• Attempts to register multiple accounts with YallaBet.com.
• Large deposits using multiple prepaid cards within a single session.
• Deposits significantly exceeding standard betting behaviour for that customer.
• Minimal wagering activity despite substantial deposits, followed by withdrawal requests without legitimate winnings.
• Frequent deposit and withdrawal cycles without reasonable explanation.
• Sudden or unexplained changes in betting patterns or transaction volumes.
• Requests or inquiries about transferring funds between accounts, including within affiliated platforms.
• Transactions inconsistent with the customer’s known financial profile, occupation, or income.
• Suspicious behaviour during high-risk gameplay, such as coordinated betting or chip-dumping.

YallaBet.com may also require information about the source of funds (SoF) and source of wealth (SoW). This may include declarations supported by documents such as bank statements, employment records, payslips, or tax filings.

Failure to provide the required information may result in temporary restrictions, suspension of deposits/withdrawals, or full account closure until the matter is resolved.

If concerns regarding money laundering, terrorist financing, or deliberately incorrect information arise, YallaBet.com reserves the right to restrict access to the account and retain deposited funds as permitted by applicable law.

In certain cases, customers may be asked to provide:

• A live selfie holding their identification document,
• A clearer or certified/notarized copy of an identification document if standard verification fails.

Until satisfactory verification is completed, YallaBet.com may postpone, withhold, or decline payments to or from the customer’s account.

By accepting these terms, you authorize YallaBet.com to perform identity, verification, and background checks to meet AML and KYC obligations.

3.3. Identifying Politically Exposed Persons (PEPs) and Sanctioned Individuals
Handling Politically Exposed Persons (PEPs) and sanctioned individuals on YallaBet.com involves strict compliance procedures overseen by our Risk and Compliance Team.

3.3.1. Customer Due Diligence (CDD)
YallaBet.com conducts comprehensive KYC checks at registration. This includes collecting and verifying the customer’s full name, date of birth, address, identification documents, and payment information.

3.3.2. Enhanced Due Diligence (EDD)
EDD is applied to high-risk customers, including PEPs or individuals from sanctioned jurisdictions. This may involve detailed background checks, source-of-funds assessments, and continuous account monitoring throughout the customer relationship.

3.3.3. Screening Procedures
Our screening measures may include:

• PEP and sanctions list screening using updated databases maintained by:
  • The United Nations,
  • OFAC (Office of Foreign Assets Control),
  • The European Union and UK sanctions authorities,
  • National governmental sanctions registries.
    
    
• Third-party screening services, including automated KYC/AML platforms, to ensure efficient detection and monitoring of PEPs and sanctioned individuals.

4. Definition of Money Laundering
Money laundering involves actions intended to conceal the origin of funds derived from illegal activity. This includes converting, transferring, or disguising financial proceeds to make them appear legitimate. YallaBet prohibits all forms of money laundering and implements detection tools and internal controls to prevent such activity on its platform.

5. Customer Due Diligence (CDD)
Customer Due Diligence is carried out to verify identity, assess risk, and establish the legitimacy of customer activity. YallaBet collects and analyses information about its customers to ensure compliance with AML regulations. CDD procedures apply throughout the customer relationship and may be supplemented by ongoing monitoring.

Customers failing CDD checks may be refused service, suspended, or reported to authorities when required.

6. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied to customers who present higher money laundering or terrorist financing risk. EDD may be triggered by unusual transaction behaviour, large or frequent deposits, connections to high-risk jurisdictions, or identification as a Politically Exposed Person (PEP).

EDD may include:

• Verification of source of funds
• Verification of source of wealth
• Additional identity checks or face-recognition procedures
• Restrictions on deposits or withdrawals until reviews are completed

Where EDD cannot be satisfied, YallaBet may terminate the business relationship.

7. Politically Exposed Persons (PEPs) & Sanctions Screening
All customers are screened against global PEP and sanctions lists. If a customer is identified as a PEP, enhanced monitoring and stricter verification measures apply. Customers appearing on sanctions lists will be refused service, and their accounts will be suspended or closed immediately.

Screening is ongoing and updated regularly using automated third-party tools.

8. Transaction Monitoring
8.1 General Monitoring Obligations
YallaBet.com reserves the right to monitor all player transactions on the platform to prevent money laundering, terrorist financing, and any unlawful or prohibited activities. It is strictly forbidden to use YallaBet.com or its systems to facilitate illegal money transfers. Customers must not engage in any activity that is fraudulent, unlawful, or intended to disguise the origin of funds, including but not limited to money laundering or the financing of terrorism.

8.2 Reporting to Authorities and Third Parties
YallaBet.com retains the right to notify relevant authorities, regulatory bodies, payment service providers, banks, credit card companies, and other financial institutions if suspicious, fraudulent, or unlawful activity is detected. Such disclosure may include providing information about your identity, account activity, or financial transactions when required for compliance or investigative purposes.

8.3 Customer Acknowledgements
By using YallaBet.com, you acknowledge and confirm that:

• 8.3.1. The personal details you provide when opening your account, including your name and address, are accurate and truthful.
• 8.3.2. You are the legal and rightful owner of all funds deposited into your YallaBet.com account at any time.

8.4 Continuous Transaction Monitoring & Enforcement
In accordance with AML obligations, YallaBet.com implements continuous transaction monitoring to identify activity that appears unusual, inconsistent with the customer’s known profile, or indicative of potential financial crime.

If we suspect that you are involved in fraudulent, illegal, or improper behaviour—including money laundering, terrorist financing, account misuse, or violation of our Terms & Conditions—YallaBet.com may immediately suspend or terminate your access to the Website. Your account may be blocked during the investigation, and we reserve the right to withhold all funds associated with the account until the matter is resolved.

Suspicious account activity may result in an internal investigation by the AML and Compliance Team. Based on the findings, the AML Team will determine whether a Suspicious Activity Report (SAR) must be submitted to the relevant Financial Intelligence Unit (FIU), in accordance with applicable laws and regulatory requirements.

8.5 Internal Reporting Procedure (Suspicious Activity Reports)
Employees or consultants who identify unusual or suspicious activity must file a written report (SAR) to the Money Laundering Reporting Officer (MLRO / AMLCO). The report must include detailed, factual, and comprehensive information to support an accurate assessment.

A SAR should include, where applicable:

• 8.5.1. Complete identifying information about the individuals involved
• 8.5.2. Detailed description of the suspicious activity and the individual’s involvement
• 8.5.3. Specific types of money laundering behaviours observed
• 8.5.4. Dates or time periods in which the activity occurred
• 8.5.5. Status of the transactions (completed, in progress, or attempted)
• 8.5.6. Locations or platforms where the activity took place
• 8.5.7. Methods or channels used to conduct the activity
• 8.5.8. Amount(s) of money involved
• 8.5.9. Clear rationale explaining the basis for suspicion
• 8.5.10. Any supporting documentation available to assist the MLRO in determining the appropriate actions

This process ensures accurate escalation and compliance with regulatory expectations.

8.6 Authorization for Verification Checks
By accepting the Terms & Conditions of YallaBet.com, you authorize the Company to conduct verification checks (“Checks”) whenever necessary, either at our discretion or upon request by third parties such as payment providers or regulatory authorities. You acknowledge that you may be required to provide additional documents or information—including verification of deposits or payment methods—to confirm the accuracy of previously submitted details.

Failure to comply with verification or transaction monitoring procedures may result in account restrictions, suspension, or closure, as well as withholding of funds where required by law.

9. Reporting Suspicious Activity
Suspicious activities detected by automated systems, employees, or manual review must be reported to YallaBet’s Money Laundering Reporting Officer (MLRO). The MLRO reviews the case and determines whether a Suspicious Activity Report (SAR) must be filed with the appropriate authorities.

Customers must not be informed when they are under investigation or when a SAR has been submitted, as this is considered “tipping-off” and is strictly prohibited.

10. Record Keeping
YallaBet securely stores all verification documents, transaction records, monitoring logs, and internal investigations for a minimum of five years from the customer’s last activity or account closure, or longer if required by law. Records are accessible only to authorized personnel.

11. Prohibited Activities
YallaBet strictly prohibits:

• Use of stolen or fraudulent payment methods
• Third-party deposits or withdrawals
• Account sharing or creation of duplicate accounts
• Using VPNs or proxies to bypass country restrictions
• Structuring transactions to avoid AML checks
• Bonus abuse or chip dumping intended to disguise fund transfers
• Attempts to manipulate wagering patterns to withdraw illicit funds

Violations may result in account closure, confiscation of funds, and reporting to authorities.

12. Internal Staff Responsibilities & Training
Employees receive mandatory AML/CFT training during onboarding and at regular intervals. Training covers recognition of suspicious behaviour, verification procedures, confidentiality obligations, and internal escalation processes.

Staff must follow all AML procedures and promptly report concerns to the MLRO.

13. Audits & Policy Review
The AML Policy is reviewed at least annually or when regulatory changes occur. Internal audits are conducted to assess whether AML controls, verification checks, and monitoring procedures remain effective and compliant with regulatory expectations.

14. Data Protection & Confidentiality
All customer data collected for AML purposes is handled under strict confidentiality and processed in accordance with the YallaBet Privacy Policy and applicable data protection laws. Information is shared only with regulatory or law enforcement authorities when required.

15. Disciplinary Action
Employees who breach AML procedures may face disciplinary action, including termination. Customers who violate AML rules may have their accounts restricted, suspended, or permanently closed. Funds may be withheld pending investigation, and authorities may be notified.

16. Policy Approval
This AML/CFT Policy has been approved by the Senior Management of Wonderland Ltd. and is mandatory for all departments and partners associated with YallaBet.