Scope and Purpose

This KYC Policy sets out the Know-Your-Customer controls implemented by 33bmw (the Operator) to comply with applicable anti-money laundering and counter-terrorist financing laws, provide risk‑based customer due diligence, and govern ongoing monitoring, data handling, and reporting obligations. The policy applies to all personnel acting on behalf of 33bmw and to all customer interactions conducted through the 33bmw platform.

Definitions

  • KYC: Know-Your-Customer procedures governing customer identity and risk assessment.
  • AML: Anti-Money Laundering laws and related controls designed to detect and prevent misuse of products and services.
  • CTF: Counter-Terrorist Financing requirements governing the detection and reporting of funds or activity related to terrorism.
  • PEP: Politically Exposed Person, or a person described in equivalent public office designations, requiring enhanced due diligence when applicable.
  • CDD: Customer due diligence, including identity verification and risk assessment.
  • EDD: Enhanced due diligence for higher‑risk customers or transactions.
  • MLRO: Money Laundering Reporting Officer responsible for the oversight and escalation of suspicious activity concerns.
  • Restricted jurisdiction: Any jurisdiction where 33bmw is prohibited or where compliance would breach applicable law or licensing conditions.

Regulatory Framework and Risk‑Based Approach

33bmw shall comply with all applicable AML and CTF statutes, sanctions regimes, and relevant gaming regulations. A risk‑based framework is employed to determine the level of due diligence, monitoring, and verification required for each customer and transaction. The intensity of controls increases with the assessed risk level and adjusts in response to changes in customer behavior or profile.

Onboarding and Identity Verification

  • Registration and Acceptance: A customer must be registered and undergo identity verification before participating in services beyond test or demonstration modes where permitted by law.
  • Identity Verification: Acceptable identity evidence includes a valid government‑issued passport, national ID card, or driver’s license; residential address evidence such as a recent utility bill, bank statement, or official correspondence dated within the last 2 months; and, when required, documentation confirming the source of funds.
  • Documentation Requirements: Submitted documents must be clear, legible, and current. Scanned copies are not acceptable; submissions may be requested directly from the customer for authenticity checks.
  • Enhanced Verification Triggers: Additional checks may be requested for funding sources, wealth verification, or when identity cannot be established from primary documents. A selfie with the identity document may be requested in appropriate cases.

Thresholds and Verification Triggers

We may require verification documentation or additional information when the customer’s cumulative deposits or withdrawals reach €500 or the equivalent in the customer’s currency. In such cases 33bmw may temporarily restrict access to withdrawal functionality or suspend activity until verification is completed. Delays or suspension will only occur for reasonable periods and to the extent necessary to complete verification.

Ongoing Monitoring and Risk Management

All customer activity is subject to ongoing monitoring for patterns indicating deviations from expected behavior, including unusual deposit or withdrawal activity, velocity of transactions, or inconsistent data. Transactions and account histories are retained for audit and compliance purposes. High‑risk accounts, including those identified as Politically Exposed Persons or whose activity triggers enhanced due diligence, are subject to additional screening and more frequent reviews.

Prohibited Jurisdictions

33bmw does not permit the creation of accounts or the processing of deposits from individuals located in jurisdictions where online gambling is prohibited or restricted by applicable law or licensing conditions. The Operator maintains a restricted‑region policy and shall apply sanctions, licensing guidance, and international obligations in relation to the eligibility of customers located in or connected to prohibited jurisdictions.

Documentation and Verification Procedures

The following procedures apply to verification checks and ongoing due diligence:

  • Identity verification shall be completed prior to enabling substantial gaming or financial activity beyond a basic account;
  • Acceptable documents include a valid passport, ID card, or driver’s license; a recent utility bill or equivalent document confirming address; and, where applicable, proof of payment method used (e‑wallet, card statement, or bank statement).
  • Additional verifications may include source of funds, origin of wealth, or requests for selfies with identity documents to confirm authenticity.
  • If information provided is false, inaccurate, or incomplete, 33bmw may suspend or terminate the customer’s account and refuse access to Services in whole or in part.

Suspicious Activity Reporting

Staff must report any knowledge or reasonable grounds to suspect money laundering or terrorist financing to the MLRO. A Suspicious Activity Report (SAR) shall be filed with the appropriate regulatory or law enforcement authorities in accordance with applicable law. Staff shall not disclose suspicions to customers prior to regulatory notification, and no adverse action shall be taken against staff reporting in good faith.

Data Privacy, Retention, and Information Sharing

Personal data collected by 33bmw is processed in accordance with applicable data protection laws. The data controller is 33bmw, and data is used to provide services, manage accounts, and comply with legal obligations. Personal information remains confidential and is not disclosed to third parties except as necessary to provide services, comply with law, or protect 33bmw’s rights. Data will be retained for a minimum of eight (8) years from the end of the customer relationship or as otherwise required by law. Customers have rights to access, correct, or request deletion of their personal data in accordance with applicable data protection laws. Data transfers to third parties and cross‑border sharing shall be subject to appropriate safeguards and contractual commitments. Cookies and similar technologies may be used to manage sessions and security.

Roles and Governance

Senior management provides direction and oversight of AML/CTF strategy and risk management. An appointed MLRO is responsible for implementation, escalation of suspicious activity, and liaison with regulatory authorities. The policy requires ongoing staff training on AML/CTF indicators and internal controls to maintain compliance with applicable laws and standards.

Customer Rights and Inquiries

Customers may request access to their personal data, corrections of inaccurate information, or restrictions on processing, subject to legal allowances. Requests should be directed to the contact channels published by 33bmw. Consents given for data processing may be withdrawn consistent with legal obligations, with such withdrawal not affecting data processing already performed or required to fulfill contractual obligations.

Amendments and Governing Law

This policy is governed by the laws applicable to 33bmw’s licensing jurisdiction. 33bmw may amend this policy from time to time to reflect changes in law, regulatory guidance, or risk management practices. Material changes will be communicated to customers in accordance with applicable requirements and may require customer acknowledgment where mandated.