ANTI-MONEY LAUNDERING (AML) POLICY

1. PURPOSE

This Anti-Money Laundering ("AML") Policy establishes the principles, procedures, and controls implemented by Diam.bet ("the Company," "we," "us," or "our") to prevent, detect, and report money laundering, terrorist financing, fraud, and other illicit financial activity.

The Company is committed to complying with all applicable AML laws, regulations, and industry best practices relevant to its business operations.

2. SCOPE

This policy applies to:

• All Company officers, owners, contractors, and employees
• All users of the Diam.bet platform
• All transactions processed through the platform, including cryptocurrency deposits and withdrawals

This policy covers customer onboarding, transaction monitoring, recordkeeping, and reporting obligations.

3. BUSINESS MODEL OVERVIEW

Diam.bet operates as an online gaming entertainment platform with two distinct operating modes:

3.1 International Crypto Casino (Non-US Users)

For users outside the United States, Diam.bet operates as a cryptocurrency-based casino platform. Key characteristics:

• Deposits and withdrawals conducted via cryptocurrency (Bitcoin, Ethereum, Solana, and other supported digital assets)
• Real-value gaming with cryptocurrency balances
• KYC verification required for withdrawals
• Operated from Costa Rica in compliance with applicable gaming regulations

3.2 US Social Casino Mode (US Users Only)

For users located in the United States, Diam.bet operates exclusively as a social casino platform. Key characteristics:

• No real-money wagering or gambling
• Virtual currency used for entertainment gameplay only (Gold Coins and Diam Coins)
• No purchase necessary to play
• Entertainment purposes only with no cash value

3.3 Restricted Jurisdictions

Users from the United States and other restricted jurisdictions are strictly prohibited from accessing the international crypto casino mode. Any user found to be circumventing geographic restrictions, misrepresenting their location, or creating accounts to access real-money gaming features when prohibited will have their account permanently banned and all funds forfeited.

4. AML RISK ASSESSMENT

The Company has assessed its AML risk based on:

• Customer profile and geographic location
• Transaction types (cryptocurrency transfers)
• Geographic exposure and restricted jurisdictions
• Payment methods (cryptocurrency wallets, blockchain transactions)

The Company considers its AML risk moderate and implements controls proportionate to its size, transaction volume, and operational structure. Cryptocurrency transactions carry inherent AML considerations, and the Company employs blockchain analytics and monitoring tools where appropriate.

5. CUSTOMER DUE DILIGENCE (KYC)

5.1 Account Registration

All users must:

• Be at least 18 years of age (or higher where required by law)
• Provide accurate registration information including country of residence
• Accept the platform's Terms of Service

5.2 Identity Verification (KYC)

Identity verification is required prior to any withdrawal and may include:

• Government-issued photo ID
• Proof of address
• Email and phone verification
• Selfie verification / liveness check

The Company reserves the right to request additional documentation where necessary, including source of funds verification for large transactions.

5.3 Enhanced Due Diligence

Enhanced due diligence measures may be applied to users who:

• Conduct high-volume transactions
• Originate from higher-risk jurisdictions
• Exhibit unusual transaction patterns
• Are identified as Politically Exposed Persons (PEPs)

6. GEOGRAPHIC RESTRICTIONS & ENFORCEMENT

The Company enforces strict geographic access controls:

• Users must declare their country of residence during registration
• US users are automatically placed in Social Casino mode with no access to real-money gaming
• Users from other restricted jurisdictions where online gaming is prohibited are blocked from the crypto casino
• Use of VPNs, proxies, or other methods to circumvent geographic restrictions is strictly prohibited

Enforcement: Any user from the United States or another restricted country found to have created an account for real-money or international play will have their account permanently banned. All balances will be forfeited. This policy applies equally to all restricted jurisdictions.

7. TRANSACTION MONITORING

The Company monitors user activity for suspicious behavior, including but not limited to:

• Unusual transaction volume or velocity
• Rapid deposits followed by immediate withdrawal attempts
• Use of multiple accounts or wallet addresses
• Inconsistent user behavior patterns
• Attempts to bypass verification or geographic restrictions
• Structuring transactions to avoid reporting thresholds
• Transactions involving sanctioned wallet addresses

Automated and manual reviews are used to identify potentially suspicious activity. Blockchain analytics may be employed to trace cryptocurrency transaction origins.

8. SUSPICIOUS ACTIVITY HANDLING

If suspicious activity is detected, the Company may:

• Temporarily suspend the account pending investigation
• Conduct enhanced due diligence
• Request additional verification and source of funds documentation
• Decline or reverse transactions where permitted
• Permanently terminate the account
• Forfeit account balances where legally permissible

The Company cooperates fully with payment processors, financial institutions, and lawful authorities as required.

9. SANCTIONS & PEP SCREENING

The Company does not knowingly allow:

• Sanctioned individuals or entities
• Politically Exposed Persons (PEPs) without enhanced review
• Users listed on applicable sanctions lists (e.g., OFAC, EU, UN)
• Transactions involving sanctioned wallet addresses or jurisdictions

Screening is conducted as part of the KYC process where applicable.

10. CRYPTOCURRENCY-SPECIFIC CONTROLS

Given the cryptocurrency nature of the platform, additional controls include:

• Wallet address binding to verified user accounts
• On-chain transaction verification for deposits
• Withdrawal limits and cooling-off periods
• Monitoring for transactions from mixing services or privacy-focused protocols
• Blockchain confirmation requirements before crediting deposits

11. RECORD KEEPING

The Company maintains records related to:

• Customer identification and verification documents
• Transaction activity including blockchain transaction hashes
• Wallet addresses associated with user accounts
• AML reviews and decisions

Records are retained for a minimum of five (5) years or as required by applicable law.

12. REPORTING OBLIGATIONS

Where required by law or contractual obligations, the Company will:

• Report suspicious activity to relevant authorities
• Respond to lawful requests for information
• Cooperate with payment processors, blockchain analytics firms, and regulators

13. TRAINING & AWARENESS

Personnel responsible for compliance receive training appropriate to their role, including:

• Identifying suspicious activity and cryptocurrency-specific red flags
• Escalation procedures
• AML responsibilities and regulatory requirements

14. GOVERNANCE & RESPONSIBILITY

The Company has designated a responsible individual to oversee AML compliance.

AML Compliance Contact:
Email: [email protected]

15. POLICY REVIEW

This AML Policy is reviewed periodically and updated as necessary to reflect:

• Changes in laws or regulations
• Changes in business operations
• Developments in cryptocurrency regulation
• Processor or banking requirements

16. CONFIDENTIALITY

This policy is an internal compliance document and may be shared with payment processors, banking partners, and regulators for verification purposes.