PapiBet Know Your Customer (KYC) Policy

Effective Date: 17 March 2026

PapiBet.com is operated by Genesis Enterprise Ltd, registration number 15915, with registered address at PO Box 1212, Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros, and is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros, under License No. ALSI-202503002-FI1 (hereinafter referred to as "PapiBet", the "Company", "we", "us", or "our").

1. INTRODUCTION

This Know Your Customer ("KYC") Policy outlines the principles, procedures, and standards implemented by PapiBet to identify, verify, monitor, and manage its customers in accordance with applicable Anti-Money Laundering ("AML"), Counter-Terrorist Financing ("CTF"), sanctions compliance requirements, and regulatory obligations.

The Company is committed to maintaining the highest standards of integrity, transparency, responsible gaming, and lawful business conduct and applies robust customer due diligence measures designed to prevent:

• Money laundering;
• Terrorist financing;
• Fraud and identity theft;
• Corruption and bribery;
• Sanctions violations;
• Financial crime;
• The misuse of gambling services for unlawful purposes.

By registering an account, accessing our services, or conducting transactions through the Platform, customers acknowledge and agree to comply with:

• This KYC Policy;
• The Terms and Conditions;
• The Privacy Policy;
• The Responsible Gambling;
• Any additional compliance procedures implemented by the Company from time to time.

2. PURPOSE AND SCOPE

This Policy establishes the Company's framework for:

• Customer identification;
• Customer verification;
• Risk assessment;
• Ongoing customer monitoring;
• Source of Funds verification;
• Source of Wealth assessments;
• Financial crime prevention measures.

This Policy applies to:

• All registered customers;
• All deposits and withdrawals;
• All payment methods;
• All gaming products and services;
• All jurisdictions in which the Company lawfully operates.

3. REGULATORY COMPLIANCE

The Company maintains and enforces KYC and AML procedures consistent with:

• Applicable laws and regulations;
• Licensing requirements;
• International best practices;
• Risk-based customer due diligence principles;
• Internal compliance standards.

The Company reserves the unrestricted right to:

• Request customer information;
• Verify customer identity;
• Re-verify existing customers;
• Obtain additional supporting documentation;
• Conduct enhanced compliance reviews.

Verification activities may occur:

• Prior to account activation;
• Prior to deposits;
• Prior to withdrawals;
• During gameplay activities;
• Following unusual account behaviour;
• At periodic review intervals;
• Upon account closure.

Failure to provide requested information or documentation may result in:

• Account restrictions;
• Transaction delays;
• Suspension of services;
• Withdrawal limitations;
• Permanent account termination.

The Company may request identity, address, payment method, Source of Funds, or any additional verification documents at any time during the customer relationship, including before or after deposits, withdrawals, account activity, or previous successful verification procedures.

3.1 Compliance Oversight

The Company maintains appropriate internal compliance functions responsible for the implementation, monitoring, and enforcement of its KYC and AML procedures.

Such responsibilities may include:

• Customer due diligence oversight;
• Enhanced Due Diligence reviews;
• Suspicious activity assessments;
• Regulatory communications;
• Record retention supervision;
• Employee compliance awareness;
• Internal monitoring and control procedures.

The Company shall cooperate fully with competent authorities and regulatory bodies in connection with applicable compliance obligations.

4. DEFINITIONS

For the purposes of this Policy:

• KYC means Know Your Customer procedures.
• CDD means Customer Due Diligence.
• EDD means Enhanced Due Diligence.
• AML means Anti-Money Laundering.
• CTF means Counter-Terrorist Financing.
• PEP means Politically Exposed Person.
• SOF means Source of Funds.
• SOW means Source of Wealth.
• Beneficial Owner means the natural person who ultimately owns or controls assets, accounts, or financial resources.

5. RISK-BASED APPROACH

The Company applies a comprehensive risk-based approach to customer identification and ongoing monitoring.

Customer risk assessments may consider:

5.1 Geographical Factors

• Country of residence;
• Nationality;
• Geographic exposure;
• High-risk jurisdictions;
• Sanctions-related restrictions.

5.2 Transactional Factors

• Transaction volumes;
• Deposit frequency;
• Withdrawal behaviour;
• Payment methods utilized;
• Unusual activity patterns.

5.3 Customer Factors

• Occupation;
• Business activities;
• Source of Funds indicators;
• Source of Wealth indicators;
• PEP status;
• Adverse media findings.

Customers may be classified as:

• Low Risk;
• Standard Risk;
• High Risk.

The Company reserves the right to apply Enhanced Due Diligence measures whenever elevated risks are identified.

The Company shall periodically review and update its internal risk assessment methodologies to reflect operational developments, emerging financial crime risks, regulatory requirements, and material changes to its products, services, jurisdictions, or customer base.

6. CUSTOMER DUE DILIGENCE (CDD)

The Company conducts Customer Due Diligence procedures designed to establish and verify customer identity and assess the legitimacy of customer activities.

CDD measures may include:

• Identification and verification of customers;
• Verification of residential address information;
• Verification of payment methods;
• Source of Funds assessments;
• Source of Wealth assessments where appropriate;
• PEP screening;
• Sanctions screening;
• Adverse media reviews;
• Ongoing monitoring activities;
• Periodic re-verification procedures.

Customer accounts may remain subject to continuous review throughout the duration of the business relationship.

7. INFORMATION COLLECTED FROM CUSTOMERS

The Company may collect, process, verify, and periodically update information including, but not limited to, the following:

7.1 Personal Information

• Full legal name;
• Date of birth;
• Nationality;
• Country of residence;
• Residential address;
• Email address;
• Telephone number;
• Account username.

7.2 Identification Information

• Passport details;
• National identity card information;
• Driver's licence information;
• Government-issued identification records;
• Verification photographs;
• Tax identification information where applicable.

7.3 Financial Information

• Payment method details;
• Deposit records;
• Withdrawal records;
• Bank account information;
• Cryptocurrency wallet addresses;
• Transaction history;
• Source of Funds documentation;
• Source of Wealth information.

7.4 Technical Information

• IP addresses;
• Device identifiers;
• Browser information;
• Operating system data;
• Login timestamps;
• Geolocation data where legally permissible;
• Fraud-prevention metadata.

7.5 Compliance Information

• PEP assessments;
• Sanctions screening outcomes;
• Adverse media findings;
• Enhanced Due Diligence records;
• Internal compliance reviews;
• Risk classification information.

The Company reserves the right to request any additional information reasonably required to:

• Comply with legal obligations;
• Conduct customer due diligence;
• Verify financial transactions;
• Prevent financial crime;
• Protect the integrity of the Platform.

8. IDENTITY VERIFICATION REQUIREMENTS

The Company may require customers to provide satisfactory evidence of identity before permitting certain activities or processing withdrawals.

Acceptable proof of identity documents include:

• Valid passports;
• National identity cards;
• Driver's licences;
• Other government-issued photographic identification approved by the Company.

Identification documents must:

• Be valid and unexpired;
• Clearly display the customer's full legal name;
• Display the customer's date of birth;
• Include a recognizable photograph;
• Show all document edges;
• Contain visible security features where applicable;
• Match the information supplied during registration.

The Company retains sole discretion regarding document acceptability.

8.1 Mandatory verification

The Company may require mandatory verification in circumstances including, but not limited to:

• Prior to the first withdrawal request;
• When cumulative transaction thresholds are reached;
• Where suspicious or unusual activity is detected;
• Where discrepancies exist in customer information;
• When multiple payment methods are used;
• Where fraud prevention or account security concerns arise;
• When required by applicable laws, regulations, or licensing obligations;
• At any time at the sole discretion of the Company.

8.2 Verification Timeframes

The Company shall make reasonable efforts to review and process submitted verification documents within commercially reasonable timeframes.

Verification timelines may vary depending upon:

• Customer risk classifications;
• The completeness of submitted documentation;
• Enhanced Due Diligence requirements;
• Source of Funds investigations;
• Regulatory reporting obligations;
• The necessity for additional independent verification procedures.

The Company reserves the right to suspend withdrawals, transactions, or account activities until all verification requirements have been satisfactorily completed.

9. PROOF OF ADDRESS REQUIREMENTS

Customers may be required to provide evidence of residential address.

Acceptable documents include:

• Utility bills;
• Bank statements;
• Government correspondence;
• Tax records;
• Municipal documentation;
• Insurance statements;
• Other reliable documents approved by the Company.

Proof of address documents should:

• Be issued within the previous three (3) months;
• Clearly display the customer's full legal name;
• Reflect the registered residential address;
• Originate from an independent and reliable source.

Additional documentation may be requested where necessary.

10. PAYMENT METHOD VERIFICATION

To safeguard customers and maintain the integrity of financial transactions, the Company may require verification of payment instruments used on the Platform.

10.1 Bank Cards

Customers may be requested to provide:

• An image of the front side of the card;
• Visibility of only the first six (6) and last four (4) digits;
• Concealment of middle digits;
• Concealment of CVV/CVC security codes.

10.2 Electronic Wallets

Customers may be required to provide:

• Screenshots confirming ownership;
• Account statements;
• Transaction confirmations;
• Additional supporting evidence.

10.3 Bank Accounts

Verification measures may include:

• Bank statements;
• Confirmation letters;
• Ownership verification documents;
• Beneficial ownership information.

10.4 Cryptocurrency Transactions

Where applicable, the Company may require:

• Evidence of wallet ownership;
• Blockchain transaction confirmations;
• Source of Funds documentation;
• Enhanced Due Diligence procedures.

Additional verification requirements may be imposed based on:

• Transaction values;
• Customer risk profiles;
• Regulatory obligations.

11. THIRD-PARTY PAYMENTS

The Company generally prohibits third-party financial transactions.

Accordingly:

• Deposits from third parties are prohibited;
• Withdrawals to third-party accounts are prohibited;
• Customers must use payment methods registered in their own names;
• Exceptions require explicit compliance approval.

Failure to comply may result in:

• Transaction reversals;
• Withdrawal delays;
• Account restrictions;
• Permanent account closure.

12. ENHANCED DUE DILIGENCE (EDD)

Enhanced Due Diligence procedures may be applied in circumstances including, but not limited to:

• High-value transactions;
• Unusual transaction patterns;
• Customers residing in high-risk jurisdictions;
• Politically Exposed Persons;
• Sanctions-related concerns;
• Adverse media findings;
• Source of Funds uncertainties;
• Fraud prevention considerations.

EDD measures may include:

• Additional identity documentation;
• Independent verification procedures;
• Source of Wealth assessments;
• Source of Funds documentation;
• Senior compliance approvals;
• Enhanced transaction monitoring;
• Periodic reviews.

13. SOURCE OF FUNDS (SOF)

The Company reserves the right to request evidence regarding the lawful origin of funds utilized on the Platform.

Examples may include:

• Employment income documentation;
• Salary statements;
• Business ownership records;
• Corporate documentation;
• Tax returns;
• Investment portfolios;
• Property sale agreements;
• Inheritance records;
• Banking statements;
• Other legitimate evidence.

Failure to establish the legitimacy of funds may result in:

• Account restrictions;
• Withdrawal limitations;
• Enhanced Due Diligence procedures;
• Account termination.

14. SOURCE OF WEALTH (SOW)

Where appropriate, the Company may require customers to explain the broader origin of accumulated wealth.

Supporting documentation may include:

• Corporate ownership records;
• Historical investment statements;
• Trust documentation;
• Asset sale agreements;
• Tax declarations;
• Inheritance records;
• Financial statements;
• Other documentation reasonably requested by the Company.

Source of Wealth assessments may be conducted where:

• Enhanced Due Diligence is required;
• High-value activities occur;
• Regulatory obligations require additional scrutiny;
• Elevated financial crime risks are identified.

15. POLITICALLY EXPOSED PERSONS (PEPs)

The Company maintains procedures designed to identify and manage risks associated with Politically Exposed Persons ("PEPs"), their family members, close associates, and other persons presenting heightened compliance risks.

The Company may conduct:

• PEP screening during customer onboarding;
• Periodic PEP re-screening throughout the business relationship;
• Adverse media checks;
• Enhanced Due Diligence procedures;
• Senior management approvals where required.

The following categories may be subject to additional scrutiny:

• Domestic PEPs;
• Foreign PEPs;
• Officials of international organizations;
• Immediate family members of PEPs;
• Close associates and beneficial owners connected to PEPs.

The Company reserves the right to:

• Request additional documentation;
• Conduct Source of Funds reviews;
• Conduct Source of Wealth assessments;
• Apply enhanced monitoring measures;
• Restrict or terminate customer relationships presenting unacceptable risks.

16. SANCTIONS COMPLIANCE

The Company maintains procedures designed to comply with applicable international sanctions requirements.

Sanctions screening may include, but is not limited to:

• United Nations sanctions lists;
• European Union sanctions lists;
• United Kingdom sanctions regimes;
• OFAC sanctions programs;
• Other applicable governmental restrictions.

The Company reserves the right to:

• Reject customer registrations;
• Restrict transactions;
• Freeze or suspend accounts where legally permitted;
• Refuse withdrawals pending compliance reviews;
• Terminate business relationships presenting sanctions concerns.

Customers subject to applicable sanctions measures shall not be permitted to access the Company's services.

17. PROHIBITED JURISDICTIONS

The Company does not knowingly establish or maintain business relationships with:

• Residents of prohibited jurisdictions;
• Individuals subject to sanctions measures;
• Sanctioned entities;
• Persons acting on behalf of prohibited individuals or organizations;
• Customers attempting to circumvent geographical restrictions.

The Company reserves the right to:

• Block access to the Platform;
• Restrict gameplay activities;
• Refuse deposits or withdrawals;
• Close customer accounts without prior notice where legally permissible.

18. BENEFICIAL OWNERSHIP

The Company may require customers to disclose information concerning beneficial ownership structures where necessary.

Customers may be required to provide:

• Ownership declarations;
• Corporate documentation;
• Trust agreements;
• Shareholding records;
• Additional evidence demonstrating ultimate control over assets or payment methods.

The Company reserves the right to verify:

• The identity of ultimate beneficial owners;
• Sources of funds connected to beneficial owners;
• Sources of wealth associated with business structures;
• The legitimacy of corporate relationships.

Failure to provide satisfactory information may result in account restrictions or termination.

19. NON-FACE-TO-FACE VERIFICATION

Recognizing the nature of online gaming services, the Company applies enhanced controls to non-face-to-face customer relationships.

Additional verification measures may include:

• Live identification procedures;
• Selfie verification requirements;
• Device consistency checks;
• Multi-factor authentication;
• Additional Source of Funds documentation;
• Enhanced Due Diligence reviews.

The Company reserves the right to request:

• Certified documentation;
• Notarized copies;
• Official translations;
• Additional independent verification evidence.

19.1 Electronic Verification Systems

The Company may utilize electronic verification systems, third-party identity verification providers, sanctions screening tools, fraud-prevention technologies, biometric verification solutions, and other automated compliance mechanisms to verify customer identities and assess customer risk profiles.

Electronic verification measures may include:

• Database verification checks;
• Identity authentication services;
• Device fingerprinting technologies;
• IP intelligence and geolocation analysis;
• Biometric and facial recognition verification;
• Liveness detection procedures;
• Sanctions and watchlist screening services;
• Fraud-prevention and risk-scoring systems.

The use of electronic verification methods shall not limit the Company's right to request additional documentary evidence or conduct manual compliance reviews at any time.

20. ONGOING MONITORING

Customer relationships remain subject to continuous monitoring throughout their lifecycle.

Monitoring activities may include:

20.1 Transaction Monitoring

• Deposit activities;
• Withdrawal patterns;
• Transaction frequencies;
• High-value transfers;
• Unusual account behaviour.

20.2 Account Monitoring

• Device usage patterns;
• Geographic inconsistencies;
• Login activities;
• Multiple account detection;
• Fraud indicators.

20.3 Risk Profile Reviews

• Changes in customer circumstances;
• Updated sanctions screening;
• PEP re-assessments;
• Source of Funds reviews;
• Enhanced Due Diligence requirements.

The Company may request renewed verification documentation at any time.

21. SUSPICIOUS ACTIVITY REPORTING

The Company reserves the right to delay, reject, suspend, restrict, or report transactions involving suspected unlawful conduct.

Circumstances warranting additional scrutiny may include:

• Unusual transaction patterns;
• Rapid movement of funds;
• Structuring activities;
• Fraud indicators;
• Identity inconsistencies;
• Sanctions concerns;
• Suspicious payment methods.

The Company may:

• Conduct internal investigations;
• Escalate matters to compliance personnel;
• Cooperate with competent authorities;
• Submit reports where legally required;
• Suspend customer activities pending investigation.

The Company shall fully cooperate with:

• Regulators;
• Financial institutions;
• Law enforcement agencies;
• Government authorities;
• Judicial bodies.

22. NON-TIPPING-OFF REQUIREMENTS

Where required by applicable laws or regulatory obligations, the Company may refrain from informing customers regarding:

• Internal investigations;
• Compliance reviews;
• Suspicious transaction reports;
• Regulatory communications;
• Requests received from competent authorities.

Customers acknowledge that:

• Certain information may be withheld;
• Investigations may occur without prior notice;
• Regulatory reporting obligations may supersede customer communications.

23. MINORS AND IDENTITY MISREPRESENTATION

The Company strictly prohibits access to its services by:

• Persons under eighteen (18) years of age;
• Persons below the legal gambling age applicable in their jurisdiction;
• Individuals utilizing false identities.

The following actions constitute material breaches of this Policy:

• Submission of forged documents;
• Use of altered identification materials;
• Identity theft;
• False declarations;
• Misrepresentation of personal information;
• Circumvention of verification procedures.

The Company reserves the right to:

• Immediately terminate affected accounts;
• Void transactions where legally permitted;
• Report unlawful conduct to competent authorities.

24. FAILURE TO COMPLETE VERIFICATION

The Company may suspend, restrict, or permanently terminate customer accounts where:

• Requested information is not provided;
• Verification documents are incomplete;
• Information supplied is inaccurate or misleading;
• Fraud concerns arise;
• Money laundering risks are identified;
• Regulatory obligations require intervention.

Consequences may include:

• Withdrawal delays;
• Account limitations;
• Suspension of services;
• Permanent closure;
• Confiscation, return, or withholding of funds where legally permissible.

The Company retains sole discretion in determining whether verification requirements have been satisfied.

25. RECORD RETENTION

The Company shall retain:

• Customer identification records;
• Verification documentation;
• Transaction histories;
• Compliance reviews;
• Risk assessments;
• Internal investigation materials.

Customer identification records, verification documentation, transaction records, and other compliance materials shall be retained for a minimum period of five (5) years following the termination of the business relationship, or for any longer period required by applicable laws, licensing conditions, or regulatory obligations.

Retention periods shall additionally be determined according to:

• Applicable laws;
• Licensing requirements;
• Regulatory obligations;
• Legitimate business purposes.

Following expiration of applicable retention periods, information shall be:

• Securely deleted;
• Anonymized;
• Archived in accordance with legal requirements.

26. DATA PROTECTION AND CONFIDENTIALITY

All customer information collected pursuant to this Policy shall be processed, stored, and protected in accordance with:

• The Privacy Policy;
• Applicable data protection legislation;
• Regulatory requirements;
• Industry best practices.

Information may be disclosed to:

• Competent authorities;
• Regulatory bodies;
• Financial institutions;
• Service providers;
• Law enforcement agencies;
• Judicial authorities.

Such disclosures shall occur only where:

• Legally required;
• Contractually authorized;
• Reasonably necessary for compliance purposes.

The Company implements appropriate safeguards designed to protect customer information against:

• Unauthorized access;
• Loss or destruction;
• Misuse;
• Alteration;
• Disclosure.

27. POLICY AMENDMENTS

The Company reserves the right to amend, revise, or update this Policy at any time.

Changes may result from:

• Legislative developments;
• Regulatory amendments;
• Licensing requirements;
• Operational considerations;
• Risk management enhancements.

The latest version published on the Company's website shall:

• Supersede previous versions;
• Become effective upon publication;
• Govern all customer relationships going forward.

Customers are encouraged to review this Policy periodically.

28. CONTACT INFORMATION

Questions concerning this KYC Policy or compliance matters may be directed to:

Support Team
Email: [email protected]

Additional compliance inquiries may be submitted through the contact channels made available on the Company's official website.

This KYC Policy may be published in multiple languages. In case of any inconsistency, the English-language version shall prevail.