Aml Policies

Introduction and Scope

Jilihh maintains an AML and CFT program to detect and deter money laundering and the financing of terrorism on the platform. The policy applies to all users, accounts, payments and transactions conducted on Jilihh services. It complies with applicable law and with recognized international standards.

Eligibility: participation is limited to individuals who are at least 18 years old in their jurisdiction and who have the legal capacity to gamble. The platform may require age and identity verification as part of the KYC process.

Risk Based Framework

Jilihh operates a risk based approach to identify and mitigate AML/CFT risk. The framework recognises three principal risk categories: country or geographical risk, customer risk and transaction risk.

• Country risk: assessment of the user residence or domicile against defined risk indicators including high risk or non cooperating jurisdictions and credible sources expressing concern.
• Customer risk: assessment of factors such as Politically Exposed Person status, sanctions, adverse media, and unusual account behavior.
• Transaction risk: monitoring of pattern and magnitude of activity for anomalies such as rapid, large or cross jurisdiction transfers.

Know Your Customer and Verification

Verification is triggered at defined thresholds or when risk signals exist. Standard verification is performed when the total value of transactions through the user account reaches or exceeds USD 1 000, when risk indicators exist, or at the request of the compliance function.

Required documents and data include a government issued identification document, documents proving the user address, and data relating to the payment instruments used for deposits and withdrawals. Where applicable, the cardholder name must match the account holder, and for wallets the registered email must match the account. The user may be asked to provide additional documents or information in accordance with local regulatory requirements. In some cases the user may be asked to engage with the support function for additional verification procedures such as live or videoconference verification.

Enhanced Due Diligence

Enhanced due diligence applies for Politically Exposed Persons and for users from high risk jurisdictions or circumstances requiring heightened scrutiny. Additional verification includes documentation on the source of wealth and the source of funds, and final approval by senior management before the relationship proceeds. The platform may request periodic updates to verification records to maintain risk controls.

Ongoing Monitoring and Suspicious Activity

All user activity is subject to ongoing monitoring for suspicious indicators. Examples of suspicious activity include multiple cards or payment methods used in a short period, unusual payment errors, inconsistent device identifiers, mismatched geolocation data, and reluctance to complete verification. Suspicions are escalated to the anti fraud function for risk assessment and appropriate action, which may include temporary restrictions or referral to competent authorities as required by law.

Transaction Monitoring and Payment Integrity

Deposits and withdrawals must comply with identification checks and ownership verification. Third party payments are prohibited. If a deposit is made from a payment instrument that cannot be definitively linked to the user, the platform will use a traceable payout route to a verified instrument owned by the user. The platform does not accept payments from anonymous instruments and will not withdraw funds to an instrument not owned by the user where ownership cannot be established.

Record Keeping and Data Protection

Documents and data collected under verification and all financial records are stored and processed in accordance with applicable law and data protection standards. The platform maintains records for the periods required by law and in alignment with GDPR and local data protection statutes. Access to records is restricted to authorized personnel and protected by appropriate technical measures and encryption where required by law.

Policy Amendments and Notice

This AML/CFT policy may be amended at any time. Changes become effective fourteen days after publication on the platform. It is the responsibility of the user to review updates. Continued use of the services after notice constitutes acceptance of the revised policy.

Compliance Contact

For questions or to review verification information, users may contact the Jilihh compliance team at [email protected].