Rainbet.com AML Policy

Last Updated: April 8, 2025

1. Introduction

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

Rainbet.com is dedicated to preventing money laundering and terrorist financing. This Anti-Money Laundering Policy describes the measures we apply to support compliance with applicable legal and regulatory obligations, including the EU’s Sixth Anti-Money Laundering Directive (6AMLD), FATF Recommendations, and the General Data Protection Regulation (GDPR).

2. Objective of the Policy

To protect our platform, users, and financial environment, Rainbet.com applies a three-stage account verification procedure together with ongoing transaction monitoring. The purpose of these controls is to verify user identities, confirm that financial activity is legitimate, and reduce risks connected to money laundering.

3. Legal Framework

Rainbet.com structures its AML controls in line with:

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

4. Definition of Money Laundering

Money laundering includes:

• Hiding the source of proceeds obtained through criminal activity.
• Converting or transferring unlawful assets in order to disguise their origin.
• Knowingly acquiring, possessing, or using property derived from criminal conduct.
• Assisting, supporting, or enabling any of the actions listed above.

Money laundering remains unlawful even where the underlying criminal offense took place in another jurisdiction.

5. Governance Structure

• The General Management of RBGAMING N.V. retains overall responsibility for AML compliance.
• An Anti-Money Laundering Compliance Officer (AMLCO) is responsible for overseeing implementation, reporting, and risk assessment activities.

6. Customer Due Diligence (KYC)

Rainbet.com carries out identity verification during account registration and in connection with certain transactions.

Required Documents:

• Government-issued identification such as a passport, ID card, or driver’s license, together with:
  • A selfie showing the user holding the ID and a handwritten note containing 6 randomly generated numbers.
  • All corners of the document clearly visible.
  • Only necessary data fields, including name, date of birth, nationality, gender, and photo, unless further information is required.
• Proof of Address:
  • Address verification is performed electronically through two databases. If electronic verification is unsuccessful, a manual document may be required, such as a utility bill, government letter, or bank statement issued within the last 3 months.
• Source of Funds:
  • Evidence may include employment records, proof of business ownership, inheritance documentation, or investment records.

7. Transaction Monitoring

Rainbet.com uses a three-level transaction monitoring process:

1. Automated Monitoring: AI-based systems identify unusual patterns, including:
   • Repeated deposits and withdrawals with little or no gameplay.
   • Use of multiple or different payment methods.
   • Changes in account behavior or geographic activity.
2. Employee Review:
   • Trained staff review AI-generated alerts and conduct manual checks where required.
3. Manual Audits:
   • Higher-risk users and accounts showing suspicious activity are subject to manual audits.

All suspicious transactions are escalated to the AMLCO.

8. Risk-Based Approach (EWRA)

Rainbet.com performs an annual Enterprise-Wide Risk Assessment (EWRA), reviewing:

• Products and services offered.
• Types of transactions.
• User profiles and geographic exposure.
• Delivery channels and developing risks.

The AMLCO uses the results of the EWRA to update and adjust AML policies where necessary.

9. Reporting Suspicious Activity

All employees are required to report suspicious activity to the AML team. The AMLCO:

• Assesses the report.
• Submits a Suspicious Activity Report (SAR) to the relevant Financial Intelligence Unit (FIU), where required.
• May terminate user accounts based on the outcome of the review.

10. Record Keeping

In accordance with applicable legal requirements:

• KYC records are kept for 10 years after account closure.
• Transaction records are securely stored, offline and encrypted, for 10 years.

11. Staff Training

Rainbet.com ensures that:

• All employees complete mandatory AML training each year.
• New employees receive academic AML training appropriate to their role.
• Training materials are updated in response to regulatory developments.

12. Data Protection

Rainbet.com complies with the GDPR. User data:

• Is stored securely.
• Is not disclosed unless disclosure is required by law, including in connection with AML investigations.

13. Contact & Complaints

For AML or KYC-related questions, please contact:

Email: support@rainbet.com

14. Version Control

Version: 1.2

Last Reviewed: April 8, 2025

Next Scheduled Review: April 2026