WinWin KYC and AML Policy

WinWin applies KYC and AML procedures to confirm the identity of each account holder, prevent fraudulent conduct, and ensure full compliance with financial crime regulations. These measures form the foundation of a secure and transparent environment for all users.

The following standards are upheld through these policies:

• Fair play is maintained across all platform activities, ensuring no user gains an unfair advantage through deceptive means.
• User safety is protected by preventing unauthorised access, fraud, and financial exploitation.
• Transparency is preserved through clear, consistent application of verification and monitoring procedures.
• Regulatory compliance is ensured by adhering to all applicable legal obligations under Bangladesh law and the platform’s licensing conditions.

Every new user registered on the platform is required to complete ID verification before accessing full account functionality, including deposits, withdrawals, and participation in certain activities. Document submission is a mandatory step and must be completed accurately and in a timely manner.

The following categories of documents may be requested during the verification process:

• A valid government-issued photo identification document, such as a national identity card, passport, or driving licence.
• Proof of current residential address, provided through a recent utility bill, bank statement, or officially issued correspondence.
• Confirmation of ownership of the payment method used for deposits or withdrawals, which may include a bank statement, screenshot, or relevant account documentation.
• In certain cases, additional personal data or supporting documents may be requested as part of enhanced due diligence procedures.

WinWin maintains a comprehensive set of security measures designed to detect, prevent, and report money laundering, terrorism financing, and any other form of financial crime on the platform. These controls are applied consistently across all user accounts and transactions.

The following AML controls are in operation:

• Continuous transaction monitoring is conducted to identify irregular or suspicious activity across all account operations.
• Automated detection systems are in place to flag unusual patterns, high-frequency transactions, or anomalies inconsistent with normal account behaviour.
• Enhanced due diligence is applied in high-risk circumstances, including large deposits or withdrawals, changes in account behaviour, or indicators of potential financial crime.
• Reviews of large or unusual fund transfers are carried out to assess the source and legitimacy of funds involved.
• Risk scoring is assigned to user accounts based on behavioural patterns, transaction history, and other relevant factors, with higher-risk accounts subject to additional scrutiny.
• Sanctions screening and Politically Exposed Person (PEP) checks are performed during registration and on an ongoing basis to ensure compliance with applicable restrictions.
• Reporting obligations are fulfilled by submitting relevant information to competent authorities in Bangladesh and, where required, to international bodies, in cases of confirmed or suspected financial crime.

Certain actions are strictly prohibited on the platform in order to maintain the integrity of KYC and AML compliance and to protect the broader user base. Any attempt to circumvent these controls will result in enforcement action.

The following activities are prohibited:

• Operating multiple accounts under the same or different identities, commonly referred to as multi-accounting.
• Submitting forged, altered, or stolen documents during the identity check or any other verification process.
• Attempting to use the platform for the purpose of laundering funds obtained through illegal activity.
• Manipulating platform systems, exploiting technical vulnerabilities, or interfering with fair play in any form.
• Sharing, selling, transferring, or otherwise granting access to a registered account to any third party.
• Using payment instruments that belong to another individual or entity, including shared or borrowed financial accounts.
• Providing false or misleading personal data at any stage of registration, ID verification, or account management.

Any breach of the KYC or AML policy will be treated as a serious compliance matter and will trigger immediate enforcement action proportionate to the nature of the violation. Depending on the circumstances identified, the platform may apply the following measures: temporary or permanent account suspension, freezing or confiscation of funds linked to suspicious activity, cancellation of bets or associated winnings, and reporting of the account holder to the relevant competent authorities in Bangladesh where applicable under law.

Each registered user bears direct responsibility for ensuring that all personal data provided to the platform is accurate, complete, and kept up to date at all times. Users are required to complete the identity check process within the timeframe specified by the platform and to respond promptly to any requests for additional documents or clarifications. Only payment methods that are legally owned by the account holder may be used for deposits and withdrawals, and any attempt to use third-party instruments will be treated as a policy violation. Users are also expected to report any suspicious activity they encounter, whether relating to their own account or to the conduct of other users, through the appropriate support channels. Failure to meet these responsibilities may result in restricted account access or further action in accordance with the platform’s compliance procedures.

WinWin is committed to upholding fair play and full transparency across all platform operations, ensuring that every user benefits from a safe and properly regulated environment. These principles are applied consistently and without exception to all registered accounts.

The following principles guide the platform’s approach to user safety and compliance:

• Full compliance with KYC and AML standards as required by applicable regulatory requirements in Bangladesh and under the platform’s licence.
• Strict confidentiality and protection of personal data in accordance with applicable data privacy obligations.
• Ongoing transaction monitoring and review processes to detect and address suspicious activity at the earliest opportunity.
• Active prevention of manipulation, collusion, and any conduct that undermines fair play or the integrity of the platform.
• Dedicated user support on matters relating to account protection, identity check procedures, and compliance queries.
• Shared responsibility between the platform and its users in maintaining a secure and legally compliant environment.
• Equal conditions applied to all account holders, ensuring that verification standards and security measures are enforced uniformly and without discrimination.