ZunaBet Know Your Customer (KYC) Policy and Procedures

1. Policy Overview

1.1 Purpose and Scope

This Know Your Customer (KYC) Policy establishes comprehensive procedures for customer identification, verification, and ongoing monitoring at ZunaBet. This policy applies to all customers, transactions, and business relationships within our gaming platform.

1.2 Regulatory Framework

Strathvale Group Ltd (hereinafter "ZunaBet" or "Company"), is a company duly incorporated under the laws of Anjouan. ZunaBet operates the website www.zunabet.com under the license issued by the Anjouan Gaming License.

As a reputable global business and a leading player in the gambling industry, ZunaBet expressly condemns, prohibits, and rejects the use of its website and services for any form of illicit activity, including money laundering and terrorist financing.

ZunaBet has implemented a set of measures and internal procedures to help identify and deter illicit activities on its website, ensuring compliance with applicable Anjouan regulations regarding Anti-Money Laundering and the Prevention of Terrorism Financing, as well as following industry best practices.

1.3 Policy Objectives

• Verify customer identity and prevent identity fraud
• Ensure compliance with age restrictions and gambling regulations
• Detect and prevent money laundering and terrorist financing
• Maintain accurate customer records for regulatory reporting
• Protect minors from accessing gambling services
• Implement effective risk-based customer due diligence

2. Customer Identification Requirements

2.1 Mandatory Identification Elements

All customers must provide verified information, including:

• Full legal name (as appears on government identification)
• Date of birth with age verification (minimum 18 years)
• Permanent residential address
• Contact information (email address and phone number)
• Nationality and country of residence
• Source of funds declaration for deposits exceeding €2,000

2.2 Enhanced Due Diligence Triggers

Additional verification requirements apply for:

• Customers from high-risk jurisdictions
• Deposits or withdrawals exceeding €5,000 in any 30-day period
• Unusual transaction patterns or suspicious activity
• Customers identified as Politically Exposed Persons (PEPs)
• Beneficial owners of corporate accounts

2.3 Simplified Due Diligence

Reduced verification may apply for:

• Customers from low-risk EU member states
• Transactions below €1,000 with established account history
• Electronic money institutions regulated within the EU
• Customers verified through trusted third-party services

3. Document Verification Standards

3.1 Primary Identity Documents

Acceptable documents include:

• Valid passport with a machine-readable zone
• National identity card (EU/EEA countries only)
• Driving license with photograph (where accepted by local regulation)

Document Requirements:

• Must be government-issued and currently valid
• Clear, color photograph showing the full document
• All text must be legible without obstruction
• Document must match the registered customer name exactly

3.2 Proof of Address Documentation

Accepted address verification includes:

• Utility bills (electricity, gas, water, internet, or telephone)
• Bank or credit card statements
• Government correspondence (tax documents, voter registration)
• Tenancy agreements or mortgage statements
• Municipal tax bills or council tax documents

Address Document Standards:

• Issued within the last 90 days
• Shows the customer's full name and complete address
• Issued by a recognized institution or authority
• Must match the address provided during registration

3.3 Payment Method Verification

For card deposits, customers must provide:

• Photograph of a payment card (front and back)
• First 6 and last 4 digits visible, middle digits obscured
• CVV code must be completely hidden
• Cardholder name must match the registered account name

For e-wallet verification:

• Screenshot of the account holder details page
• Transaction history showing a deposit to ZunaBet
• Account verification status confirmation

3.4 Additional Documentation

When required by risk assessment:

• Employment verification or business registration
• Bank reference letters or financial statements
• Source of wealth documentation
• Politically Exposed Person declarations
• Beneficial ownership information

4. Verification Procedures

4.1 Initial Registration Verification

4.2 Document Review Process

Automated Verification:

• Optical Character Recognition (OCR) technology
• Document authenticity checks using security features
• Cross-reference with government databases where available
• Facial recognition matching for photo IDs

Manual Review:

• Trained KYC specialists review flagged documents
• Additional verification requests are issued when necessary
• Complex cases escalated to senior compliance officers
• External verification services are utilized for high-risk cases

4.3 Verification Timeline

• Level 1: Immediate upon registration
• Level 2: 24-48 hours for standard documents
• Level 3: 72-96 hours, including manual review processes
• Complex cases: Up to 14 business days with customer communication

5. Ongoing Monitoring and Maintenance

5.1 Periodic Review Requirements

Annual Reviews:

• All customer profiles are reviewed annually
• Document expiration monitoring and renewal requests
• Risk rating reassessment based on activity patterns
• Enhanced due diligence for high-risk customers

Triggered Reviews:

• Significant changes in transaction patterns
• Large or unusual deposit/withdrawal requests
• Address or contact information changes
• Adverse media or sanctions list appearances

5.2 Customer Communication

Document Requests:

• Clear explanation of required documents
• Secure document upload portal with encryption
• Progress tracking and status updates
• Multiple communication channels (email, SMS, account notifications)

Rejection and Resubmission:

• Detailed rejection reasons with examples
• Guidance on correct document submission
• Customer support assistance available
• Escalation procedures for dispute resolution

6. Special Circumstances

6.1 Minor Protection Measures

Age Verification:

• Mandatory age checks before account activation
• Cross-reference with electoral rolls and credit databases
• Immediate account suspension for suspected minors
• Cooperation with parental control organizations

Account Closure Procedures:

• Immediate suspension of underage accounts
• Full refund of deposits minus any winnings
• Reporting to relevant authorities as required
• Implementation of additional safeguards to prevent re-registration

6.2 Politically Exposed Persons (PEPs)

Identification Process:

• Screening against comprehensive PEP databases
• Enhanced due diligence for identified PEPs
• Senior management approval for account opening
• Increased monitoring of all transactions

Ongoing Obligations:

• Quarterly review of PEP status
• Source of wealth verification
• Enhanced transaction monitoring
• Regular senior management review

6.3 Corporate and Trust Accounts

Additional Requirements:

• Certificate of incorporation or trust deed
• Beneficial ownership information (25% threshold)
• Authorized signatory identification
• Corporate resolution authorizing gambling activities

Ongoing Monitoring:

• Annual corporate structure updates
• Beneficial ownership change notifications
• Enhanced transaction monitoring
• Regular corporate standing verification

7. Data Protection and Security

7.1 Information Security

Technical Safeguards:

• 256-bit SSL encryption for data transmission
• Secure document storage with access controls
• Regular security audits and penetration testing
• Multi-factor authentication for staff access

Operational Security:

• Need-to-know access principles
• Regular staff security training
• Incident response procedures
• Vendor security requirements

7.2 Data Retention

Retention Periods:

• Active customer records: Throughout the relationship plus 5 years
• Closed account records: 5 years from account closure
• Transaction records: 5 years from the transaction date
• Suspicious activity reports: 5 years from report date

Disposal Procedures:

• Secure deletion using certified methods
• Certificate of destruction for physical documents
• Regular data purging schedules
• Compliance with data protection regulations

8. Customer Rights and Support

8.1 Customer Rights

• Clear information about KYC requirements
• Reasonable timeframes for document processing
• Secure handling of personal information
• Appeals process for adverse decisions
• Access to personal data upon request

8.2 Support Services

Available Assistance:

• Dedicated KYC support team
• Multi-language customer service
• Video call verification for complex cases
• Alternative document acceptance procedures
• Escalation to management for disputes

Communication Channels:

• Email: kyc@zunabet.com
• Live chat: Available 24/7
• Phone support: Business hours in customer time zones
• Secure messaging: Through the customer account portal

9. Policy Governance

9.1 Policy Management

• Annual policy review and update
• Regulatory change impact assessment
• Staff consultation and feedback incorporation
• Board of Directors approval for significant changes
• Customer notification of material policy changes

9.2 Compliance Monitoring

• Monthly compliance reporting to senior management
• Quarterly reports to the board of directors
• Annual regulatory compliance certification
• External compliance consultant engagement as needed