1. Introduction
Bankroll is committed to preventing money laundering, terrorist financing, and other financial crime. Our Anti-Money-Laundering (AML) and Know-Your-Customer (KYC) program is aligned with the Financial Action Task Force (FATF) recommendations and the regulatory framework of the Anjouan Gaming Authority. This policy sets out the controls we apply to every player account.
2. Know Your Customer
All players must provide a valid email address, self-declared date of birth, and self-declared country of residence at signup. Before processing your first withdrawal, you will be required to complete identity verification through our KYC partner, Sumsub. This typically involves uploading a government-issued photo ID and taking a short selfie for biometric matching. Verification is usually completed within minutes.
We may refuse to open an account, freeze an existing account, or reject a withdrawal if identity verification fails or if the information you provide cannot be reliably matched to a real person.
3. Enhanced Due Diligence
Accounts that exceed $10,000 in cumulative deposits will be placed into enhanced due diligence (EDD). EDD may involve additional identity checks, verification of the device(s) used to access the account, and a review of your playing patterns for signs of structuring or layering.
4. Source of Funds
Accounts that exceed $25,000 in cumulative deposits will be required to complete a source-of-funds questionnaire. Acceptable documentation includes recent pay stubs, bank statements, a letter from an employer, tax filings, or proof of sale of assets. Accounts that fail to complete the questionnaire within a reasonable time may be suspended pending review.
5. PEP & Sanctions Screening
As part of KYC, every player is screened against politically exposed person (PEP) lists and against international sanctions lists including OFAC, the UN consolidated list, and the EU sanctions list. Matches trigger manual review by our compliance team. Accounts belonging to individuals on active sanctions lists will be closed and any balance held pending regulatory guidance.
6. Suspicious Activity Reporting
Bankroll files suspicious activity reports with the Anjouan Financial Intelligence Unit (FIU) where required by law. Examples of activity that may trigger a report include rapid deposit-and-withdrawal patterns with minimal play, deposits from mixed or tumbled wallet sources, and refusal to cooperate with EDD or source-of-funds requests. We do not notify players when a report has been filed, as doing so may constitute “tipping off” under applicable law.
7. Implementation Disclaimer
Actual identity verification integration is handled by Sumsub under FATF-aligned AML procedures (see Phase 61). The KYC, PEP/sanctions, and source-of-funds workflows described above represent the policy framework of Bankroll. The live Sumsub integration is planned for a future release; until then, manual verification may be performed by our compliance team using equivalent procedures. Withdrawals will not be processed without successful verification.
