WinWin KYC & AML Policy
This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy explains how the WinWin platform identifies each account holder, monitors payments, and manages suspicious activity for users in Bangladesh. The policy sets out the security measures, regulatory requirements, and reporting obligations that apply to online casino and sportsbook services operated under local law.
Purpose of KYC & AML
The KYC and AML framework on the platform applies to every customer to support identity check procedures, prevent fraud, and combat financial crime in Bangladesh. These measures are designed to protect user safety, maintain account protection, and support responsible gaming in line with applicable regulatory requirements.
The KYC and AML system aims to guarantee:
- Fair play for all registered users and equal conditions during betting and gaming activity
- User safety through structured ID verification and document submission standards
- Transparency in how personal data is requested, verified, and used for compliance
- Ongoing transaction monitoring for suspicious activity and unusual behaviour
- Compliance with anti-money laundering, counter-terrorism financing, and other regulatory requirements in Bangladesh
- Account protection through strict access controls and verification of the lawful account holder
KYC Requirements and Identity Check
Every new user must complete identity check and ID verification before full access to deposit, wagering, and withdrawal functions is granted. Additional document submission may be requested at any time during the customer relationship to confirm that information remains accurate and up to date.
The platform may request the following categories of documents:
- Government-issued photo identification confirming full name, date of birth, and nationality
- Proof of residential address, such as an official statement or bill displaying the user’s name and current address in Bangladesh
- Confirmation of ownership of payment methods used for deposits and withdrawals, such as bank account or mobile financial service statements
- Additional personal data or records where enhanced checks are required due to higher risk profiles
AML Measures and Transaction Monitoring
The platform applies structured AML controls and security measures to prevent money laundering, terrorist financing, and other illegal activity related to gaming and sports betting. Transaction monitoring, review of account behaviour, and appropriate reporting obligations form part of these measures.
Key AML controls include:
- Ongoing transaction monitoring of deposits, bets, transfers, and withdrawals to detect suspicious activity
- Automated detection rules that flag unusual patterns, high-risk countries, or inconsistent customer behaviour
- Enhanced due diligence for higher-risk profiles, including additional identity check, source-of-funds enquiries, and deeper document submission
- Regular review of large, frequent, or unusual transfers and payouts that may indicate possible misuse of the platform
- Risk scoring procedures to classify customers and activities according to their money laundering and terrorism financing risk level
- Screening of users against sanctions lists and politically exposed person (PEP) databases in line with Bangladesh regulatory requirements
- Reporting of suspicious transactions, attempted offences, or other relevant information to competent authorities when required by law
Prohibited Activities Supporting KYC & AML
To ensure effective KYC controls and AML compliance, the platform restricts certain behaviours that may undermine user safety, fair play, and regulatory standards. Any attempt to use the platform for purposes other than lawful gaming and betting activity is not permitted.
Prohibited activities include:
- Operating multiple accounts for the same person or using another person’s profile to bypass identity check or ID verification
- Submitting forged, altered, or stolen documents during document submission and KYC review
- Using the platform for money laundering, terrorism financing, or to disguise the origin of criminal proceeds
- Manipulating system processes, odds, bonuses, or technical features to gain unfair advantage or interfere with fair play
- Sharing, selling, or otherwise transferring access credentials, including login details, to any third party
- Using payment instruments such as bank accounts, cards, or mobile financial services that are not legally owned or controlled by the account holder
- Misrepresenting personal data, including name, address, age, or source of funds, during registration or later updates
Consequences of Non-Compliance
Any breach of this KYC and AML Policy, refusal to cooperate with verification, or indication of criminal or abusive conduct may result in enforcement action under the platform rules and Bangladesh law.
In such cases, possible measures include temporary or permanent account suspension, freezing or confiscation of funds linked to suspicious activity, cancellation of bets or winnings, reporting to competent authorities where applicable.
User Responsibilities for KYC, AML, and Account Protection
Users are responsible for providing accurate and complete personal data during registration and throughout the customer relationship, and must promptly update any information that changes, such as address or payment details. Identity check and ID verification procedures must be completed on time, including any follow-up document submission requests from the compliance team. Customers must respond in a reasonable timeframe to any request for additional documents or clarification relating to transaction monitoring, suspicious activity, or reporting obligations.
Every account holder must use only payment instruments that are legally owned and controlled by that person, and must ensure that no unauthorised party gains access to login details or devices used for gaming. Users are expected to report suspected fraud, unauthorised access, or any unusual or suspicious activity on their account to customer support so that appropriate security measures can be taken to protect account protection and user safety.
Fair Play and Transparency Standards
The platform maintains fair play and transparency as core principles to protect users, safeguard personal data, and support a safe gaming and betting environment in Bangladesh. KYC and AML controls are integrated into daily operations to promote responsible gaming, prevent manipulation, and meet all relevant regulatory requirements.
The following principles apply:
- Full adherence to KYC, AML, and counter-terrorism financing standards applicable to online casino and sportsbook operators
- Confidentiality and protection of personal data collected during registration, identity check, and ongoing verification
- Continuous monitoring and review of activity to identify suspicious activity, misuse of accounts, or attempts to bypass controls
- Prevention of manipulation, collusion, and other unfair behaviour that could undermine fair play or distort outcomes
- Availability of user support channels to address safety concerns, report issues, and obtain information on security measures
- Shared responsibility between the platform and each account holder to maintain user safety, account protection, and responsible gaming practices
- Equal treatment and consistent application of rules for all users, subject to risk-based measures where required by regulation
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