Anti-Money Laundering & Know Your Customer Policy

1. About Kitty Games

Kitty Games is operated by:

J Tech Global Limited Company Number: 16880153 Registered Office: Suite RA01, 195–197 Wood Street, London, E17 3NU, United Kingdom

Kitty Games provides skill-based gaming services through its platform, subject to applicable laws, regulations and eligibility requirements in the jurisdictions in which the service is made available.

2. Purpose of this Policy

The purpose of this Policy is to:

• prevent Kitty Games from being used for money laundering or terrorist financing;
• prevent fraud and identity theft;
• verify the identity of customers;
• protect customers and the integrity of the platform;
• identify unusual or suspicious transactions and activity;
• prevent the creation and use of fraudulent, duplicate or mule accounts;
• comply with applicable legal and regulatory requirements; and
• cooperate with competent authorities where legally required.

3. Know Your Customer (KYC)

Kitty Games may require customers to complete identity verification before accessing certain services, making deposits, entering contests, requesting withdrawals or when otherwise required by our risk controls or applicable law.

Depending on the circumstances, we may request:

• Full legal name;
• Date of birth;
• Residential address;
• Email address and telephone number;
• Government-issued identity document;
• Proof of address;
• Selfie or facial verification;
• Information concerning payment methods;
• Source of funds or source of wealth information where appropriate; and
• Any additional information reasonably required to complete our verification process.

Identity information may be verified through independent and reliable third-party verification providers. Electronic identity verification may be used where appropriate. UK Gambling Commission guidance recognizes electronic verification as one method that may be used alongside, or in appropriate circumstances instead of, documentary checks.

4. Customer Verification

We may refuse, restrict or suspend access to an account where:

• the information provided cannot be verified;
• the information provided appears inaccurate, incomplete or misleading;
• identity documents appear altered, fraudulent or invalid;
• we identify multiple accounts associated with the same customer where prohibited;
• there are concerns regarding the ownership or control of an account;
• we suspect fraudulent or unlawful activity; or
• additional verification required under our risk-based procedures has not been completed.

Customers must provide accurate and current information and must notify Kitty Games if relevant personal information changes.

5. Risk-Based Approach

Kitty Games applies a risk-based approach to AML/KYC controls.

We may consider factors including:

• customer identity and profile;
• geographic location;
• payment methods;
• transaction patterns;
• deposit and withdrawal behavior;
• account activity;
• use of multiple accounts or payment instruments;
• unusual or inconsistent activity;
• attempts to circumvent platform controls;
• information obtained from reliable third-party sources; and
• sanctions, PEP and other relevant risk indicators.

Higher-risk customers or transactions may be subject to additional verification and monitoring.

6. Enhanced Due Diligence

Where we identify increased financial crime risk, Kitty Games may apply Enhanced Due Diligence (“EDD”).

EDD may include:

• requesting additional identity documentation;
• verifying residential address;
• requesting information concerning source of funds;
• requesting information concerning source of wealth;
• reviewing transaction history;
• conducting enhanced transaction monitoring;
• obtaining additional independent information; and
• requiring additional verification before permitting deposits, contests or withdrawals.

Applicable UK AML rules require enhanced measures where a relevant person identifies a high risk of money laundering or terrorist financing.

7. Politically Exposed Persons (PEPs)

Kitty Games may conduct additional screening to identify customers who are Politically Exposed Persons (“PEPs”), their family members or known close associates where required by applicable law or our risk-based procedures.

Where appropriate, enhanced due diligence and additional monitoring may be applied.

8. Sanctions Screening

Kitty Games may screen customers against applicable sanctions and other relevant financial-crime databases.

Where a customer or transaction presents a sanctions-related concern, Kitty Games may suspend or restrict the account or transaction and take any further action required by applicable law.

9. Deposits and Payments

Customers must use payment methods that they are legally entitled to use and, where required, that are registered in their own name.

Kitty Games may restrict or reject transactions where:

• the payment method appears to belong to another person;
• the payment method presents an unacceptable financial crime risk;
• the transaction appears fraudulent or unauthorized;
• the transaction appears inconsistent with the customer’s account activity; or
• additional verification is required.

We may impose additional controls on certain payment methods or transaction patterns.

10. Withdrawals

Withdrawals may be subject to KYC and AML checks.

Before processing a withdrawal, Kitty Games may verify:

• the identity of the account holder;
• ownership or control of the relevant payment method;
• the legitimacy of the account activity;
• the source of funds where appropriate; and
• whether the withdrawal presents fraud, money laundering or other financial crime concerns.

We may delay, reject or suspend a withdrawal while an investigation or verification process is being completed. Where possible and legally permissible, withdrawals will be processed to an account or payment method belonging to the verified customer.

11. Prohibited Activities

Customers must not use Kitty Games for:

• money laundering;
• terrorist financing;
• fraud;
• identity theft;
• payment fraud;
• unauthorized use of another person’s payment method;
• creating fraudulent or deceptive accounts;
• circumventing account restrictions;
• transferring accounts to other individuals;
• using the platform to disguise the origin of funds; or
• any other unlawful activity.

12. Account Monitoring

Kitty Games may monitor account activity and transactions to identify unusual or potentially suspicious behavior.

Monitoring may include analysis of:

• deposits;
• withdrawals;
• contest participation;
• transaction frequency;
• payment instruments;
• account relationships;
• unusual changes in activity;
• linked or duplicate accounts; and
• other relevant behavioral or transactional indicators.

Current UK Gambling Commission risk guidance identifies linked/duplicate accounts and fraudulent identity documentation as significant risks for remote gaming operators.

13. Suspicious Activity

Where Kitty Games identifies activity that may involve money laundering, terrorist financing, fraud or another financial crime, we may:

• request additional information;
• restrict account functionality;
• suspend deposits or withdrawals;
• suspend or close an account;
• retain relevant funds where legally permitted;
• decline or reverse a transaction where legally permitted; and
• report the matter to the appropriate authority where required by law.

We will not disclose information where doing so would breach applicable law or interfere with a legitimate investigation.

14. Duplicate and Linked Accounts

Unless expressly permitted by Kitty Games, customers may maintain only one account.

We may identify accounts that appear to be connected through common:

• identity information;
• devices;
• IP addresses;
• payment methods;
• bank accounts;
• telephone numbers;
• email addresses; or
• other relevant indicators.

Where multiple or linked accounts create financial crime, fraud or platform-integrity concerns, Kitty Games may investigate and take appropriate action.

15. Use of Third-Party Verification Providers

Kitty Games may use independent third-party providers for:

• identity verification;
• document verification;
• facial verification;
• sanctions screening;
• PEP screening;
• fraud detection;
• transaction monitoring; and
• other compliance checks.

Third-party providers may process personal information on our behalf in accordance with applicable data protection requirements.

16. Record Keeping

Kitty Games will retain relevant AML/KYC records, including identity verification information and transaction-related information, for the period required by applicable law and our internal retention policies.

UK Gambling Commission guidance states that CDD records should generally be retained for five years from the end of the business relationship or last visit in the relevant circumstances.

17. Data Protection

Personal information collected for KYC, AML, fraud prevention and compliance purposes will be handled in accordance with our Privacy Policy and applicable data protection laws.

Customers may be required to provide personal information that is necessary for us to comply with legal, regulatory, security and financial crime prevention obligations.

18. Customer Cooperation

Customers are required to provide complete, accurate and up-to-date information when requested.

Failure to provide requested information may result in:

• restrictions on the account;
• delayed transactions;
• withdrawal restrictions;
• suspension; or
• account closure.

19. Changes to this Policy

Kitty Games may update this AML/KYC Policy from time to time to reflect changes in our services, risk environment, technology or applicable laws and regulations.

The latest version will be published on this page.

20. Contact

If you have questions regarding this AML/KYC Policy or a KYC verification request, please contact: