KYC / AML Policy

1. Purpose

This policy is intended to protect the platform against money laundering, fraud, terrorist financing, sanctions evasion, stolen identities and unlawful funds.

2. Merchant KYC

• REFILLO may verify owners/directors, business activity, contact information, bank/payment information and supporting documents.
• Higher-risk businesses, gaming/casino activity, unusual transactions or new regions may require enhanced verification and source-of-funds evidence.
• Merchants must promptly update material changes to their information.

3. Merchant Player Verification

Gaming or casino merchants must verify player age, identity, location and, where required, source of funds under applicable law. Payment access must not be provided to underage users, false identities or users from prohibited jurisdictions.

4. Transaction Monitoring

Unusual amounts, rapid repetition, shared payment sources across identities, suspicious refunds, unusual withdrawals, identity mismatches and other risk indicators may be monitored. Transactions may be paused, supporting documents requested, or settlement held where necessary.

5. Sanctions and Legal Requests

Accounts or funds may be restricted and required information disclosed in response to applicable sanctions, court orders, regulatory directions or lawful requests. Investigation details may be withheld where disclosure is not legally permitted.

6. Record Retention

KYC records, transaction records, risk decisions and audit logs may be retained as required for applicable law, dispute resolution, security and compliance.