Aml & Kyc Policy

Policy Scope and Objectives

77rp applies this AML and KYC policy to all users and accounts registered on its platform. The objective is to prevent money laundering and the financing of terrorism by employing a risk based approach, verifying customer identity, monitoring transactions, and reporting suspicious activity to the relevant authorities in compliance with applicable laws and regulations.

• Responsibilities are allocated to the designated AML Compliance Person and senior management.
• All data collected in connection with identification and verification is processed in accordance with applicable data protection requirements and retained for the period required by law.

Regulatory Framework and Risk Based Approach

77rp adopts a risk based methodology for customer due diligence. The level of due diligence applied depends on the assessed risk of the customer, the purpose and intended nature of the business relationship, and the transactions involved. The policy recognises three levels of due diligence:

1. Default Customer Due Diligence — standard verification and monitoring applied where risk factors do not indicate higher risk.
2. Simplified Customer Due Diligence — reduced information and documentation in clearly lower risk situations, without compromising regulatory standards.
3. Enhanced Customer Due Diligence — additional information, documentation, and ongoing monitoring for high risk scenarios, including enhanced scrutiny of sources of funds and wealth.

77rp may request additional information or documents at any stage if the information previously provided is incomplete, inconsistent, or cannot be verified, or as required by applicable law.

Customer Identification and Verification

Identification and verification are fundamental to opening and maintaining an account. The minimum information and documents required are:

• Full name; permanent residential address; date of birth; place of birth; nationality; and identity number or passport number where applicable.
• Unexpired government issued identification document (passport or national ID) to verify identity, with the document remaining valid for the duration of the relationship.
• Proof of residence, such as a bank statement, utility bill, or government document issued within the last six months and showing the customer’s name and current address.
• Selfie of the customer holding the identity document to verify likeness and ownership.
• Card or payment method ownership verification where deposits or withdrawals are processed by card, including a photo of the card with the middle digits and CVC obscured.

77rp may require additional documentation to confirm the legal possession and control of payment instruments or to corroborate the information supplied. Where identity or address information cannot be verified, access to certain features or the account may be limited or suspended until verification is completed.

KYC Triggers, Onboarding Flow and Statuses

Account verification is triggered by activity thresholds or regulatory requirements. The following flow applies unless otherwise required by law:

1. Trigger occurs when aggregate deposits reach the threshold of two thousand euros or a withdrawal request is submitted for any amount.
2. The customer furnishes the requested identification documents and information referenced in the Verification section above.
3. The KYC review is conducted by the dedicated KYC team, which may take up to 24 hours from receipt of documents. The customer will be informed of the outcome by secure communication channels:
4. Approval — customer may continue normal platform activity subject to ongoing monitoring.
5. Rejection — customer is informed of the reason and may need to re-submit information, if permissible.
6. More information needed — customer is notified to provide additional documents or clarification; status may not change until the information is supplied.
7. Temporarily Approved — the customer may use the platform but with deposit limitations until full verification is completed.

While in Temporarily Approved status, customers may not exceed a cumulative deposit limit of EUR 500 and may not execute withdrawals. 77rp reserves the right to adjust limits or restore full functionality upon completion of verification.

Ongoing Monitoring and Transaction Surveillance

77rp conducts ongoing monitoring of customer activity to identify unusual or suspicious transactions. Monitoring includes automated screening, review by the AML Compliance Person, and escalation when required. Relevant elements include:

• Daily reporting of transactions above EUR 1,000, including details of the counterparties and accounts involved.
• Documentation of customer identification documents and associated account history for review during monitoring.
• Evaluation of the background and purpose of complex or large transactions to determine potential AML or terrorist financing risk.
• Suspicious activity reporting to the appropriate authorities when required by law or internal policy.

Payments, Funds Flows and Third-Party Controls

Payment processing and fund movements are controlled to prevent the misuse of the platform. 77rp applies the following rules:

• Cash payments are not accepted. Funds may be deposited or withdrawn only through payment methods registered in the customer’s name.
• Deposits must originate from the customer’s own payment instruments. In cases where ownership is in doubt, 77rp may block deposits or require ownership verification.
• Refunds of winnings or other payments will be returned via the same route through which the funds originated where practicable.
• Transfers between customer accounts are prohibited unless expressly authorized by 77rp under applicable law or policy.
• If a third party processes payments for the customer, the service must furnish adequate transaction monitoring and screening in accordance with applicable law and contractual arrangements with 77rp.

Source of Funds and Source of Wealth

77rp may request information about the source of funds used to fund transactions and, in higher risk scenarios, information about the source of wealth. Acceptable evidence may include payslips, tax certificates, bank statements, or official documents evidencing income or wealth. When requested, documents must be provided in a form and language acceptable to 77rp, including certified translations if required.

Sanctions, Adverse Actors and Enhanced Due Diligence

77rp will freeze or close customer accounts where the customer is identified on sanctions lists or where there are reasonable grounds to suspect involvement in terrorist financing or other illicit activity. Enhanced due diligence may be applied to high risk customers, including PEPs or customers located in high risk jurisdictions, with additional documentation and heightened ongoing monitoring.

Record Keeping, Data Protection and Retention

77rp maintains records relating to customer identity, transactions, and related due diligence for the periods required by applicable law. All records are stored securely and processed in accordance with applicable data protection and privacy requirements and the platform’s privacy policy.

Training and Compliance Governance

77rp conducts ongoing AML training for all employees, overseen by the AML Compliance Person and senior management. Training occurs at least annually and is updated to reflect new regulatory requirements and emerging risks.

Amendments, Updates and Customer Communication

Any material changes to this policy will be communicated to customers with a minimum notice period of two weeks before they take effect. Continued use of the platform after the notice period indicates agreement to the updated policy.

Customer Acknowledgement and Rights

By registering on the platform, customers acknowledge their obligation to provide accurate information, comply with verification requests, and cooperate with 77rp’s AML and KYC procedures. Customers may be required to discontinue use if updates to information or documents are not provided within the specified timeframe.

Contact and Escalation

For questions or to submit documentation related to this policy, customers should use the official support channels within the 77rp platform or contact the designated AML compliance contact through secure channels provided by 77rp.