WinWin KYC & AML Policy
This Know Your Customer (KYC) and Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) policy explains how the WinWin online casino and sportsbook applies identity check and security measures to users in Bangladesh. The policy sets out how personal data is collected and used to meet regulatory requirements, protect the account holder, and reduce the risk of financial crime and suspicious activity on the platform.
Purpose of KYC & AML
KYC and AML procedures are applied to verify each account holder, confirm the legitimacy of funds, and support the prevention of fraud, money laundering, and terrorism financing under Bangladesh regulatory requirements. These controls help maintain user safety, account protection, and a safe environment for responsible gaming.
The KYC and AML framework aims to guarantee:
- Fair play and equal treatment of all registered users
- User safety through reliable identity check and document submission
- Transparency in how personal data is requested, reviewed, and stored
- Compliance with AML, CTF, and KYC regulatory requirements in Bangladesh
- Protection of payment flows through transaction monitoring and risk-based controls
- Account protection against unauthorised access and misuse
KYC Requirements and ID Verification
Every new user must complete KYC identity check and ID verification before full access to gaming and withdrawal services is provided. Additional checks may be requested at any time to keep information accurate and to address suspicious activity or security concerns.
During KYC, the following categories of documents may be requested for document submission:
- Government-issued photo identification (for example, national ID card, passport, or driving licence)
- Proof of current residential address (for example, recent utility bill, bank statement, or official letter showing name and address)
- Confirmation of ownership of payment methods used for deposits and withdrawals (for example, bank card evidence, e-wallet proof, or mobile financial service statement)
- Any other supporting documentation required to clarify identity, source of funds, or source of wealth under local regulatory requirements
AML Measures and Transaction Monitoring
The platform implements structured AML and CTF security measures to limit the risk of money laundering, terrorist financing, and other illegal activity. Controls are designed in line with Bangladesh laws and international standards to ensure early detection and reporting of suspicious activity.
Key AML and CTF controls include:
- Continuous transaction monitoring of deposits, bets, transfers, and withdrawals across user accounts
- Automated detection rules to identify patterns inconsistent with normal gaming behaviour or responsible gaming practices
- Enhanced due diligence for high-risk customers, high-value operations, or complex transaction structures
- Regular review of large, frequent, or unusual transfers that may indicate misuse of the platform
- Risk scoring of users and activities, adjusted for geography, product usage, payment methods, and behaviour
- Screening of users against applicable sanctions lists and politically exposed person (PEP) databases in line with regulatory requirements
- Internal escalation and, where required by law, reporting obligations to competent authorities regarding suspected money laundering or terrorism financing
- Periodic review and update of AML procedures and staff training to maintain effective security measures and account protection
Prohibited Activities Supporting KYC & AML
To maintain effective KYC and AML controls, certain behaviours are strictly restricted on the platform. Any use of the casino or sportsbook that might hide the identity of the account holder, the origin of funds, or that may disrupt fair play and transparency is prohibited.
Prohibited activities include:
- Opening or operating multiple accounts by the same individual to avoid limits, monitoring, or KYC procedures
- Using forged, altered, stolen, or borrowed identity or address documents during ID verification or document submission
- Attempting to deposit, circulate, or withdraw funds in a pattern that may resemble money laundering or terrorism financing
- Manipulating systems, odds, or game results, including using automated tools or exploiting vulnerabilities
- Sharing, selling, or otherwise providing account access to any third party, including friends, family members, or agents
- Using third-party payment instruments or accounts that are not legally and beneficially owned by the registered user
- Misrepresenting identity, personal data, source of funds, or other information requested under KYC and AML procedures
- Any conduct intended to bypass transaction monitoring, risk controls, or reporting obligations
Consequences of Non-Compliance
Breach of this KYC and AML policy, refusal to provide requested information, or any attempt to obstruct identity check, transaction monitoring, or investigation of suspicious activity may lead to enforcement measures under the platform rules and applicable law.
Possible actions 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 Account Protection
Each user is responsible for providing true, complete, and up-to-date personal data during registration and throughout the relationship. Identity check and ID verification requests must be completed within the time specified, including prompt document submission and any additional explanation requested for AML or CTF purposes. Users must only use payment methods and financial accounts in their own name to support account protection and compliance with regulatory requirements in Bangladesh. Any loss, theft, or suspected misuse of login details or payment credentials should be reported to customer support and, where appropriate, to local authorities without delay. Users are also encouraged to report any suspicious activity they observe on the platform that may relate to money laundering, fraud, or irresponsible use of gambling services.
Fair Play and Transparency Standards
The platform is committed to maintaining fair play and transparency for all users in Bangladesh, so that gaming activity remains secure, compliant, and aligned with responsible gaming principles. This policy supports a controlled environment where personal data is handled responsibly, and user safety is prioritised.
Core principles of fair play, transparency, and user protection include:
- Full alignment of KYC, AML, and CTF processes with applicable Bangladesh regulatory requirements
- Protection and confidential handling of personal data in accordance with data protection and privacy rules
- Ongoing transaction monitoring and review of behaviour to detect and address suspicious activity promptly
- Prevention of manipulation, collusion, or other unfair practices that could distort betting or game outcomes
- Dedicated user support for safety, KYC, AML, and account protection questions
- Shared responsibility where both the platform and each account holder contribute to a safe and responsible gaming environment
- Equal conditions, rules, and access to information for all users, without discriminatory treatment
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