AML Policy

Last Updated: 17 October 2025 v1.2

 

1. Introduction

This Anti-Money Laundering Policy (“AML Policy”) outlines the commitment of ZenoBet Ltd (“ZenoBet”, “the Company”, “we”, “us”) to comply with the EU's Sixth Anti-Money Laundering Directive (6AMLD), FATF Recommendations and all applicable Anti-Money Laundering (“AML”) and Countering the Financing of Terrorism (“CFT”) regulations and international best practices.

Zenobet.com is operated by ZenoBet Ltd is registered under Registration No. 16027, with its registered address at Hamchako, Mutsamudu, Autonomous Island of Anjouan, PO Box 1212, Union of Comoros, Anjouan.

ZenoBet acknowledges that its products and services may be exposed to risks of money laundering (“ML”) and terrorist financing (“TF”) and is committed to fostering a strong compliance culture to mitigate these risks.

 

2. Policy Statement and Objectives

ZenoBet strictly prohibits the use of its services for any form of illicit activity, including ML, TF, or sanctions violations.

The objectives of this AML Policy are to:

• Prevent the use of ZenoBet’s services for ML/TF;
• Implement effective systems and controls to detect, assess and mitigate AML risks;
• Comply with applicable laws, regulations, and guidance;
• Promote a culture of compliance throughout the organization.

 

To achieve these objectives, ZenoBet:

• Adopts and maintains written policies, procedures, and internal controls designed to guard against ML, TF and sanctions breaches;
• Provides regular AML/CFT training to relevant personnel;
• Conducts periodic reviews and updates of its AML framework.

 

3. Legal Framework

Rainbet.com aligns its AML measures with:

• Directive (EU) 2015/849, as amended by Directive (EU) 2018/843 and Directive (EU) 2018/1673 (6AMLD).
• Regulation (EU) 2015/847 on information accompanying transfers of funds.
• GDPR (Regulation (EU) 2016/679).
• Anjouan AML legislation.
• Relevant FATF Recommendations.

 

Definition of Money Laundering

Money laundering involves:

• Concealing the origin of criminal proceeds.
• Converting or transferring illicit assets to disguise their origin.
• Acquiring or using criminally obtained property knowingly.
• Aiding or facilitating any of the above actions.

Money laundering is illegal even when the predicate offense occurs in another jurisdiction.

 

4. Responsibilities of Employees, Directors and Officers

All employees, directors, and officers must comply with this AML Policy.

They are required to:

• Be aware of their role in preventing ML and TF;
• Report suspicious transactions to the CCO immediately;
• Participate in mandatory AML training;
• Cooperate fully during any internal or regulatory investigation.

 

Failure to comply with these obligations may result in disciplinary action.

 

5. Customer Due Diligence (KYC)

ZenoBet applies a risk-based Know Your Customer (KYC) and Customer Due Diligence (CDD) program to verify the identity of customers and assess associated ML/TF risks in accordance to its KYC Policy.

5.1. KYC Measures

ZenoBet collects and verifies customer information including, but not limited to:

• Full legal name;
• Date of birth;
• Country and residential address;
• Identification number (passport, ID card, tax ID, etc.);
• Government-issued identification document;
• Source of funds or wealth where applicable.

KYC must be completed before enabling deposits, withdrawals, or full access to the platform. Third-party service providers may be used for verification.

5.2 Enhanced Due Diligence (EDD)

When red flags are identified, ZenoBet applies Enhanced Due Diligence, which may include requesting:

• Full legal name and citizenship;
• Permanent residential address;
• Government-issued identification;
• Source of funds and wealth documentation.

EDD may also be applied for high-risk customers or when withdrawal thresholds are reached.

5.3 Excluding and Geoblocking Jurisdictions

ZenoBet does not offer services in prohibited jurisdictions.

Customers must declare their location, and IP address-based geoblocking is used to prevent access from:

• Jurisdictions where gambling services are not legally permitted;
• Sanctioned jurisdictions (e.g., Iran, North Korea, Syria, Cuba, Crimea, etc.);
• Jurisdictions subject to U.S., E.U., or international sanctions.

5.4 Screening for Sanctioned Parties

Before onboarding, customers are screened against relevant sanctions and watch lists. ZenoBet may use third-party tools to conduct blockchain or identity screening to detect sanctioned individuals or entities.

 6. Ongoing Monitoring

ZenoBet monitors customer activity continuously to identify suspicious patterns or behaviour.

6.1. Transaction Monitoring

• Automated and manual checks are used to identify “red flag” transactions including bug not limited to identifying irregularities such as:
  
  

o   Repeated deposits/withdrawals without gameplay.

o   Use of different payment methods.

o   Account behaviour or geographic changes.

 

• Suspicious deposits, withdrawals, or gameplay patterns may trigger account suspension or requests for additional information.
• IP, device, and time zone checks may be used to detect location masking.
• Higher-risk users and suspicious accounts are audited manually.

All suspicious transactions are escalated to the AMLCO.

6.2. Identification of Unusual Activity

Regular reports are run to detect unusual transaction sizes, frequency, or patterns inconsistent with a customer’s profile. Sanctions re-screening occurs periodically.

6.3. Anti-Mixing and Technological Controls (If applicable)

ZenoBet may use blockchain forensic tools (e.g., Chainalysis) to screen crypto transactions and detect use of mixers, tumblers, or high-risk addresses. Such activity may lead to account suspension or refusal of transactions.

7. Blocking and Exclusion Measures

ZenoBet may refuse onboarding or block customers who:

• Fail to provide required identification;
• Provide fraudulent or invalid documents;
• Attempt to mask their true location;
• Are from prohibited or sanctioned jurisdictions;
• Are listed on sanctions or watch lists;
• Deposit funds originating from restricted exchanges.

ZenoBet reserves the right to suspend or terminate accounts at its sole discretion.

 8. Reporting to Authorities

If a customer is identified as being on a sanctions list, or is reasonably suspected of ML, TF, or other criminal activity, ZenoBet will file a Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit (FIU) or competent authority.

Such reports are made confidentially. Customers will not be informed of any investigation or report (tipping-off is strictly prohibited).

 9. Staff Training

ZenoBet provides regular AML training to all relevant employees, covering:

• AML/CFT laws and regulations;
• Internal policies and procedures;
• Red flag indicators and reporting obligations;
• Updates on evolving risks and typologies.

 10. Record Keeping

All KYC data, transaction records, and internal reports are stored securely for the minimum period required by law and will be made available to competent authorities upon request.

 11. Policy Review

This AML Policy is reviewed periodically to ensure compliance with evolving AML/CFT laws, regulations, and industry best practices.

12. Contacting Us

For questions, concerns, or requests regarding your AML, please contact us at: 📧 support@zenobet.com or compliance@zenobet.com.