Anti-Money Laundering & Know Your Customer Policy

Parimatch is committed to maintaining the highest standards of financial compliance and integrity. Our comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy ensures protection against financial crime, money laundering, terrorist financing, and fraud while complying with international regulatory standards.

Policy Purpose:
This policy establishes mandatory procedures for customer verification, transaction monitoring, and suspicious activity reporting. All customers and employees must adhere to these standards to maintain a safe, compliant betting environment.

Our Commitment to Financial Compliance

Parimatch operates with unwavering commitment to preventing financial crime and protecting customer funds. As a licensed operator regulated by the UK Gambling Commission (License #39576) and multiple international authorities, we maintain rigorous compliance with all applicable laws and international standards.

Regulatory Commitment

Parimatch’s AML/KYC Policy is aligned with:

General Data Protection Regulation (GDPR) – EU and UK data protection standards
UK Data Protection Act 2018 – Personal data handling and privacy
UK Gambling Commission Regulations – Licensing and player protection requirements
FATF Recommendations – Financial Action Task Force international standards for AML/CFT
EU Directive 2018/843 – Fifth Anti-Money Laundering Directive (5AMLD)
National Ordinance on Penalization of Money Laundering (NOPML) – Criminal money laundering prevention
National Ordinance on Reporting of Unusual Transactions (NORUT) – Suspicious activity reporting
National Ordinance on Identification of Clients (NOIS) – Customer identification requirements
PCI DSS Level 1 – Payment Card Industry Data Security Standard
ISO 27001 – Information Security Management certification

Compliance Department

Structure & Responsibilities:

Parimatch maintains a dedicated Compliance Department responsible for:

Developing and implementing AML/KYC procedures applicable to all employees
Monitoring customer activities for suspicious transactions and patterns
Conducting customer due diligence (CDD) and enhanced due diligence (EDD)
Reporting suspicious activities to relevant authorities
Maintaining audit trails and compliance documentation
Conducting internal investigations into potential money laundering
Training staff on AML/KYC compliance requirements
Ensuring continuous policy updates aligned with regulatory changes

Department Authority:

The Compliance Department has authority to:

Request additional customer documentation at any time
Block or suspend customer accounts during investigation
Freeze transactions pending verification
Refuse service to customers who fail to comply with requirements
Report suspicious activities to regulatory authorities and law enforcement
Implement enhanced monitoring procedures for high-risk customers

Know Your Customer (KYC) Verification Process

The KYC process is mandatory for all customers before account activation and ongoing throughout their relationship with Parimatch. Comprehensive customer identification protects against identity fraud, money laundering, and terrorist financing.

Customer Due Diligence (CDD)

Mandatory Information Collection:

All customers must provide complete, accurate information during registration:

Personal Information:

Full legal name (exactly as it appears on ID)
Date of birth
Nationality and country of residence
Email address
Phone number
Permanent residential address
Occupation (for high-risk jurisdictions)

Verification Information:

Identity document number
Document expiration date
Issue country and authority

Financial Information:

Source of funds (employment, business, investments, etc.)
Annual income range
Purpose of gambling/betting

Account Information:

Username and password
Preferred currency
Payment methods

All information must be accurate and up-to-date. False information violates terms and may result in account closure and reporting to authorities.

Required Identification Documents

Primary Identity Documents (One Required):

Passport: Colored copy of first two pages showing photograph, personal details, and signature; plus page with residential address stamp (if applicable)
National ID Card: Colored copy of both sides showing photograph, personal details, and security features
Driver’s License: Colored copy of both sides (accepted as primary in some jurisdictions)
Residence Card: EU/EEA residence permits (accepted as alternative)

Document Requirements:

Documents must be current and valid (not expired)
Copies must be clear, legible, and in color
All text and security features must be visible
Photographic image must be clear and recognizable
Document must not be altered or tampered with

Proof of Address Verification

Required Address Documentation:

Customers must provide proof of residential address to verify they are the documented account owner:

Acceptable Documents (One Required):

Utility Bills: Electricity, gas, water, or internet bills (within last 3 months)
Bank Statements: Official bank statements showing customer name and address (within last 3 months)
Government Documentation: Tax returns, council tax bills, national insurance letters
Rental Agreements: Tenancy agreements showing customer name and address
Official Correspondence: Letters from government agencies, financial institutions, or utilities
Mortgage Statements: Recent mortgage or home loan statements
Council Tax Documents: Official council tax bills or notices

Document Requirements:

Document must be dated within the last 3 calendar months
Customer name must match account registration details
Full residential address must be clearly visible
Must be official documentation from recognized organizations
Cannot be a P.O. Box or business address

Phone Number Verification

Mandatory Verification:

All customers must verify their phone number:

Customer provides phone number during registration
Parimatch sends SMS verification code to the number
Customer enters code in verification field within 15 minutes
Successful verification confirms customer control of phone number

Purpose: Ensures customer actually owns the phone number provided and can receive important notifications about account security and transactions.

Verification Timeline & Activation

Standard Processing:

Initial Review: Submitted documents reviewed within 24 hours
Verification Complete: Most customers verified within 24-48 hours
Complex Cases: May take up to 5 business days
Account Status: Customers notified via email when verification complete
Betting Activation: Full betting privileges available after verification
Withdrawal Access: Only available after successful verification

If Verification Delayed:

Customers can contact support to check status
May be asked for additional documentation
Account remains accessible for review and deposits
Withdrawals remain blocked until verification complete

Enhanced Due Diligence for High-Risk Customers

Enhanced Due Diligence (EDD) procedures apply to customers classified as higher risk based on regulatory requirements, geographic location, or transaction patterns.

High-Risk Jurisdiction Customers

Comprehensive Scrutiny Applied To:

Customers from high-risk jurisdictions or territories subject to international sanctions face enhanced verification:

High-Risk Jurisdictions Include:

Countries subject to UN sanctions
Countries on FATF gray or black lists
Jurisdictions with weak AML/CFT controls
Countries with known corruption issues
Territories with limited financial regulation

Enhanced Procedures:

Senior management approval required for account opening
Detailed source of funds documentation required
Business purpose clarification mandatory
Enhanced ongoing transaction monitoring
Periodic re-verification of customer information
Possible refusal of account opening

High-Risk Customer Categories

Customers Subject to Enhanced Monitoring:

Politically Exposed Persons (PEPs): Government officials, politicians, military leaders, judges, and their family members
High-Net-Worth Individuals: Customers with deposits/withdrawals exceeding £100,000 equivalent
Business Owners: Self-employed individuals and business owners (higher fraud risk)
Cash-Intensive Businesses: Restaurants, retail, casinos, nightclubs
Professional Gamblers: Customers with large betting volumes and sophisticated strategies
Third-Party Involvement: Accounts potentially used by unauthorized third parties
Unusual Transaction Patterns: Rapid deposits and withdrawals, round-figure amounts, no betting activity

EDD Documentation Requirements

Additional Documents May Be Required:

Parimatch reserves the right to request additional documentation from high-risk customers:

Source of Funds Documentation: Bank statements showing legitimate income sources
Employment Verification: Employment letters, contracts, or business registration documents
Business Documentation: Company registration, business tax returns, ownership certificates
PEP Declarations: Customers must declare PEP status; false declaration is grounds for account closure
Beneficial Owner Information: If account represents a business, beneficial owner details required
Transaction Purpose: Explanation of intended use of account and betting patterns
Original Documents: Parimatch may request original documents for in-person verification

Transaction Monitoring & Suspicious Activity Detection

Customer monitoring continues throughout their relationship with Parimatch to detect suspicious patterns and prevent financial crime.

Transaction Monitoring Procedures

Automated Systems:

Parimatch uses advanced technology systems to detect suspicious transactions automatically:

Monitoring Parameters:

Deposit Anomalies: Unusual deposit amounts, frequency, or sources
Rapid Transactions: Quick deposits followed immediately by withdrawals
Multiple Deposits: Many deposits in short timeframe suggesting layering
Round Amounts: Identical round-figure amounts suggesting structuring
Dormant Reactivation: Inactive accounts suddenly showing high activity
Multiple Payment Methods: Using numerous different payment methods
Geographic Inconsistencies: Deposits from different countries than registered address
High-Volume Betting: Unusually high or unusual betting patterns
No Betting Activity: Funds deposited but no actual betting/gaming activity
Withdrawal Patterns: Frequent large withdrawals with minimal gambling

Suspicious Activity Identification

Red Flags Triggering Investigation:

The following indicators trigger enhanced scrutiny and investigation:

Customer refuses to provide requested documentation
Information provided contradicts other documentation
Multiple customers use same payment method
Deposits from unrelated third parties
Rapid round-figure transactions suggesting money structuring
Betting patterns inconsistent with normal player behavior
Account opened specifically for receiving payments from others
Customer’s job description doesn’t match deposit sources
Use of corporate or business accounts for personal gambling
Apparent use of aliases or multiple accounts
Large transactions with no business purpose
Geographic location conflicts with account details
Sudden changes in account activity patterns
Known association with sanctioned individuals or entities

Customer Risk Scoring

Automated Risk Assessment:

Each customer receives a risk score based on:

Risk Factors:

Geographic Risk: Country of residence and deposit origin
Behavioral Risk: Betting patterns and transaction frequency
Document Risk: Document authenticity and completeness
PEP Status: Political exposure or relationship to PEPs
Transaction Risk: Amount, frequency, and timing of transactions
Source Risk: Legitimacy of stated income sources
Historical Risk: Customer history with other operators

Risk Score Categories:

Low Risk: Standard CDD sufficient
Medium Risk: Periodic transaction review
High Risk: Enhanced monitoring and EDD required
Very High Risk: Possible account closure or service refusal

Withdrawal Restrictions & Verification Requirements

Strict controls ensure funds come from legitimate sources and withdrawals go to legitimate recipients.

Withdrawal Eligibility Requirements

Mandatory Conditions For Withdrawal:

Customers must meet all requirements before withdrawals are processed:

Customer Must:

Have completed successful identity verification (KYC)
Have provided valid proof of address
Have verified phone number on file
Provide accurate account holder information
Have received explicit approval from Compliance Department
Not be on any sanctions or exclusion lists
Not have suspicious activity flags on account
Have funds available (not pending investigation)

Account Restrictions:

Withdrawals allowed only after verification completes
Amounts over £10,000 (equivalent) require additional verification
Large withdrawals may be subject to enhanced scrutiny
Suspicious withdrawals may be delayed pending investigation
Multiple rapid withdrawals may trigger investigation

Withdrawal Method Requirements

Strict Withdrawal Rules:

Withdrawal Destination Restrictions:

Same Account Rule: Withdrawals must go to the same account used for initial deposits
Named Account: Withdrawal account must be in the exact name of the account holder
No Third Parties: Withdrawals to other individuals or entities strictly prohibited
No Transfers Between Customers: Internal transfers between Parimatch users forbidden
Bank Account Match: Withdrawal bank account must match the customer’s verified name

Verification During Withdrawal:

If withdrawal method differs from deposit method, additional verification required
Bank statement or account ownership documentation may be requested
Identification may be re-verified for large withdrawals
Multiple withdrawal methods may require separate verification for each

Withdrawal Delays & Holds

Parimatch May Delay Withdrawal If:

Identity verification is incomplete or questionable
Withdrawal method differs from deposit method (additional verification required)
Transaction shows signs of suspicious activity or potential fraud
Customer fails to provide requested additional documentation
Investigation into account activity is ongoing
Fund source is questionable or cannot be verified
Large amount requires additional compliance review
Account shows multiple risk factors

Typical Delays:

Standard Processing: 1-3 business days
Additional Verification: 3-5 business days
Investigation Pending: Up to 30 days (extended if necessary)
Customer notification required if delay exceeds 5 business days

Parimatch shares customer information with authorities as required by law and maintains comprehensive records.

Mandatory Information Sharing

Third-Party Disclosure:

Parimatch is obligated to share customer information with:

Financial Institutions:

Payment processors and banks (for transaction verification)
Credit reference agencies (for verification purposes)
Other financial service providers (for fraud prevention)

Law Enforcement & Regulatory Authorities:

UK Gambling Commission (licensing and regulatory oversight)
National Crime Agency (NCA) – Financial investigations
Her Majesty’s Revenue & Customs (HMRC) – Tax compliance
National Anti-Fraud Intelligence Bureau (NAFIB)
Police forces (criminal investigations)
International law enforcement agencies (mutual legal assistance)

Financial Intelligence Units:

FinCEN (USA Financial Crimes Enforcement Network)
Europol (European policing authority)
Other international FIUs (information exchange)

Information Disclosed:

Personal identification information
Account details and transaction history
Betting patterns and financial transactions
Communication records
Document verification results
Compliance investigation findings

Disclosure Without Consent:

By using Parimatch services, customers unconditionally consent to information sharing as required by law. Parimatch is not required to inform customers before sharing information with authorities. Such disclosure occurs without prior notification to preserve investigation integrity.

Data Retention Requirements

Record Retention Periods:

Mandatory Retention (Legal Requirements):

Customer Documentation: 5+ years after account closure or last activity
Transaction Records: Minimum 5 years (UK requirement, may be extended)
Identity Documentation: 5+ years for tax and AML purposes
Betting History: 5+ years (Gambling Commission requirement)
Email Communications: 5+ years for compliance audit trails
Investigation Records: 5+ years minimum (may be extended if ongoing)

Extended Retention (Specific Circumstances):

Active Investigations: During ongoing investigations plus 5 years post-conclusion
Disputed Transactions: 5+ years from dispute resolution
Sanctioned Customers: 5+ years or until sanctions lifted + 5 years
Legal Holds: Retained indefinitely if subject to legal proceedings

Access to Records:

Customers may request access to their records (GDPR subject access requests)
Records provided within 30 days of verified request
Some information may be redacted if disclosure compromises investigations
Charges may apply for extensive record requests (permitted under law)

Suspicious Transaction Reporting & Account Investigation

When Parimatch identifies suspicious transactions or fraudulent activity, comprehensive investigations are conducted.

Suspicious Activity Triggers

Automatic Investigation Initiated When:

Customer account displays suspicious transaction patterns
Deposits received from questionable or unverified sources
Sender and account holder details don’t match
Multiple red flags appear in transaction history
Rapid consecutive deposits and withdrawals detected
Deposits exceed customer’s verified income capacity
Customer refuses to provide requested verification documents
Evidence of potential fraud or unauthorized use
Account associated with known risk factors or watch lists
Transaction amount or pattern unusual for customer profile

Investigation Procedures

Comprehensive Investigation Process:

Phase 1: Initial Assessment (24-48 hours)

Suspicious activity documented with date and details
Risk factors analyzed and scored
Decision made on investigation scope
Preliminary findings documented

Phase 2: Evidence Collection (2-5 days)

Customer transaction records reviewed
Payment method verification conducted
Identification documentation re-examined
Communications with customer reviewed
Third-party information requested (banks, payment processors)
Compliance database checks performed

Phase 3: Analysis (3-7 days)

Evidence compiled and analyzed
Customer’s explanation considered (if provided)
Pattern analysis conducted
Comparison with known fraud patterns
Legal compliance verified
Risk assessment updated

Phase 4: Resolution (5-14 days)

Investigation conclusion documented
Action determined (account continuation or closure)
Reporting obligations fulfilled
Customer notified (if permitted by law)
Compliance file updated

Account Actions During Investigation

Parimatch May Take Following Actions:

Account Suspension:

Betting activity temporarily blocked
Deposits may be refused
Withdrawals frozen pending investigation
Customer notified (except when legally prohibited)
Duration: Until investigation concludes

Account Freeze:

All account activity blocked
No deposits, withdrawals, or betting permitted
Funds secured but inaccessible
Customer notified when possible
May be permanent if investigation reveals illegal activity

Account Closure:

Account permanently closed
Access revoked
Funds handled according to investigation findings
May be referred to authorities
Customer receives notice (when legally permitted)

Transaction Reversal:

Fraudulent transactions reversed
Illegally obtained funds seized
Refunds processed as directed by law
Victim restitution handled through legal channels

Investigation Powers

Parimatch May Request:

During investigation, Parimatch has authority to request:

Additional Identification Documents: Copies of government-issued ID, additional addresses, passport pages
Financial Documentation: Bank statements, tax returns, pay stubs, business records
Payment Evidence: Card statements, receipts, payment confirmations
Source of Funds Documentation: Proof of legitimate income or fund source
Original Documents: For in-person verification or specialist analysis
Signed Declarations: Customer affidavits regarding fund source and account use
Third-Party Information: Communication with customer’s bank or payment provider
Behavioral Information: Customer explanation of unusual transaction patterns

Failure to Comply:

Customer refusal to provide requested documentation grounds for account closure
Non-compliance indicates guilty conduct or fraudulent intent
Continued refusal reported to authorities
Account access may be blocked pending compliance

Customer Compliance Requirements & Legal Obligations

Customers must adhere to strict legal requirements and AML/KYC standards.

Customer Undertakings

By Opening Account, Customer Agrees To:

Legal Compliance:

Respect all applicable legal norms and regulations
Comply with international anti-money laundering standards
Adhere to all applicable financial crime prevention laws
Comply with sanctions and export control regulations
Follow all country-specific gambling regulations

Financial Integrity:

Guarantee that all deposited funds are legally obtained
Confirm legal ownership of all funds
Warrant right to use funds for gambling purposes
Certify funds are not proceeds of crime or illegal activities
Declare funds are not borrowed for gambling purposes

Activity Standards:

Avoid any direct or indirect involvement in illegal financial activities
Refuse participation in money laundering or terrorist financing
Avoid any transactions appearing to facilitate financial crime
Prevent use of account for fraudulent purposes
Report any suspicious activity or unauthorized access

Documentation Accuracy:

Provide completely accurate information during registration
Immediately update any changed information
Notify Parimatch of documentation expiration or changes
Maintain confidentiality of login credentials
Not share account access with other individuals

Prohibited Activities

Customers May NOT:

Use account for money laundering or terrorist financing purposes
Deposit proceeds of illegal activities or crime
Conduct transactions for sanctioned individuals or entities
Participate in fraud, identity theft, or financial crime
Use borrowed funds without full disclosure
Operate account on behalf of undisclosed third parties
Attempt to circumvent verification procedures
Provide false or misleading information to Parimatch
Use account for business purposes without disclosure
Conduct transactions exceeding realistic personal capacity
Share account with other individuals
Engage in match-fixing, fraud, or betting manipulation

Violations:

Any violation of prohibited activities results in:

Immediate account closure
Fund forfeiture (turned over to authorities)
Permanent user ban from Parimatch
Reporting to law enforcement
Potential criminal prosecution

Risk Management & Policy Limitations

Parimatch has legal rights and limitations regarding enforcement and liability.

Exceptional Account Handling

Parimatch May Refuse Service:

Customers unable to verify identity adequately
Funds showing signs of suspicious origin
Account showing high-risk transaction patterns
Customer failure to comply with documentation requests
Customers from sanctioned jurisdictions
Customers identified as PEPs without disclosure
Customers engaged in prohibited activities
Customers showing fraud indicators
Age verification failure or suspected minor
Account holder suspected identity theft victim

No Liability For Refusals:

Parimatch is not liable for:

Refusal to open account
Closure of existing account for AML/KYC reasons
Suspension of account during investigation
Refusal or delay of transactions
Loss resulting from account restrictions
Any consequential or indirect damages
Loss of betting opportunities due to investigation
Disruption from compliance procedures

Investigation Limitations

Scope of Investigations:

Investigations conducted based on available information
Investigation quality depends on documentation provided
Some evidence may be unavailable or inaccessible
Investigation conclusions based on reasonable assessment
Not every suspicious pattern indicates actual fraud
Absence of evidence doesn’t guarantee legitimate activity

Notification Restrictions:

Parimatch is NOT required to inform customers about:

Monitoring and surveillance activities
Ongoing investigations or findings
Sharing of information with authorities
Account tracking or analysis
Risk scoring or categorization
Compliance procedures or methodology

Limited Notification Circumstances:

Parimatch may notify customers when:

Providing account suspension notice
Refusing withdrawal or transaction request
Requesting additional documentation
Closing account due to AML/KYC concerns
When legally required to disclose information

No Civil Liability

Parimatch Liability Limitations:

The Company’s implementation of AML/KYC procedures, investigations, and compliance actions does NOT constitute grounds for civil liability for:

Failure to fulfill obligations to customer
Inconvenience from verification delays
Loss of betting opportunities
Account suspension or closure
Fund freezing or investigation delays
Refusal of transactions
Sharing information with authorities
Any financial losses whatsoever

Regulatory Reporting & Law Enforcement Cooperation

Parimatch actively reports suspicious activity to appropriate authorities.

Suspicious Activity Reporting (SAR)

Filing Requirements:

Parimatch is obligated to file Suspicious Activity Reports (SARs) when:

Money laundering is suspected
Terrorist financing indicators exist
Unusual transaction patterns detected
Large amounts without apparent business purpose
Structured deposits appear designed to evade thresholds
Fund sources appear questionable
Multiple red flags accumulate on account

SAR Contents:

Complete customer identification information
Detailed transaction descriptions and dates
Analysis of suspicious patterns
Rationale for suspicion determination
Reference materials and supporting documentation
Recommended investigative actions

Filing Timeline:

Filed within 10 days of suspicious activity discovery
May be filed earlier if evidence strong
Confidential filing not disclosed to customer
Customer may not be informed of SAR filing

Law Enforcement Cooperation

Information Sharing With Authorities:

Parimatch cooperates fully with law enforcement:

Responds to police inquiries and subpoenas
Provides complete information as legally required
Participates in criminal investigations
Provides testimony as witness in legal proceedings
Produces documentation as requested
Makes customer available for questioning (when requested)
Executes freeze orders from law enforcement
Reports financial crimes through proper channels

Policy Review & Regulatory Compliance Updates

This policy is reviewed and updated regularly to maintain compliance with evolving regulations.

Policy Modifications

Parimatch Reserves Right To:

Modify this policy at any time without notice
Implement enhanced procedures as regulations change
Increase verification requirements
Apply stricter standards to existing customers
Request additional documentation from current customers
Implement new technologies for verification and monitoring
Amend compliance procedures based on regulatory guidance
Update high-risk jurisdiction lists
Modify fee structures related to verification

Notification of Changes:

Material changes communicated to customers
Policy updates posted on website
Customer acceptance required for material changes
Continued use of service after modification constitutes acceptance

Regulatory Compliance Commitment

Continuous Compliance:

Parimatch commits to:

Monitor regulatory changes affecting AML/KYC procedures
Update policy in response to new regulations
Implement best practices from industry standards
Participate in industry working groups and compliance forums
Maintain relationships with regulatory authorities
Conduct regular compliance audits
Train staff on updated procedures
Invest in compliance technology and systems

Customer Acceptance & Policy Incorporation

By opening an account on Parimatch, customers unconditionally accept all terms of this AML/KYC Policy.

Binding Agreement

Customer Confirmation:

Opening and using a Parimatch account constitutes:

Full acceptance of this AML/KYC Policy
Agreement to comply with all procedures and requirements
Consent to information sharing with authorities
Acceptance of account restrictions and investigation procedures
Agreement to provide requested documentation
Acceptance of investigation and enforcement actions
Understanding of policy limitations and liability exclusions
Consent to monitoring and surveillance activities

Policy Integration

Policy Status:

This AML/KYC Policy is an integral part of:

Parimatch Customer Agreement
Terms & Conditions
Legal framework governing account usage
Compliance obligations for all users
Binding contractual terms

Conflict Resolution:

If this policy conflicts with other terms:

AML/KYC Policy takes precedence
Regulatory requirements always prevail
Least restrictive interpretation applied when ambiguous
Customer protection measures prioritized

Glossary of Key Terms

AML: Anti-Money Laundering – Procedures to prevent illegal fund usage
CFT: Counter-Financing of Terrorism – Procedures to prevent terrorist funding
CDD: Customer Due Diligence – Initial customer verification procedures
EDD: Enhanced Due Diligence – Intensive verification for high-risk customers
FATF: Financial Action Task Force – International AML/CFT standard-setting body
KYC: Know Your Customer – Customer identification and verification procedures
PEP: Politically Exposed Person – Government officials and their families
SAR: Suspicious Activity Report – Report to authorities of suspected financial crime
GDPR: General Data Protection Regulation – EU/UK data protection law
NOPML: National Ordinance Penalization of Money Laundering – Alderney AML law
NORUT: National Ordinance Reporting of Unusual Transactions – Alderney reporting law
NOIS: National Ordinance Identification of Clients – Alderney identification law

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