(AML) and (KYC) Policy

VLKNA Ltd. ("VLKNA", "we", "us", or "our") operates under the gaming license issued by the Government of Anjouan, Union of the Comoros. In accordance with our licensing obligations and international best practices, VLKNA maintains a comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) framework designed to prevent, detect, and report any activity involving money laundering, terrorist financing, fraud, or other illicit behavior.

This policy applies to all users of our platform, including players, affiliates, payment service providers, and employees involved in the onboarding, verification, or monitoring of customer activity.

1. Objectives of this Policy

Prevent and mitigate the risks of money laundering and terrorist financing on the VLKNA platform

Ensure that only properly identified and verified individuals can access our services

Comply with regulatory and licensing obligations under Anjouan law

Report suspicious activity to relevant authorities when required

Maintain an auditable, traceable, and secure onboarding and transaction monitoring process

2. Risk-Based Approach (RBA)

VLKNA employs a dynamic Risk-Based Approach to evaluate and categorize players and transactions. This approach considers:

Geographic location and residence of the user

Payment method origin and currency type (fiat or crypto)

Volume and frequency of transactions

Behavioral indicators and gameplay anomalies

Involvement in promotions, VIP status, or large-scale withdrawals

Users identified as higher risk may be subject to additional verification procedures, enhanced due diligence (EDD), and ongoing monitoring.

3. KYC Procedures

KYC is mandatory for all users requesting withdrawals, reaching predefined deposit thresholds, or engaging in flagged behavior. VLKNA’s KYC process may include:

Verification of full legal name, date of birth, nationality

Submission of valid government-issued photo ID

Proof of residential address dated within the last 3–6 months

Verification of payment method (e.g. masked card image, wallet screenshot, bank interface)

Selfie or live biometric check (in select cases)

Enhanced documentation for politically exposed persons (PEPs), or users flagged by sanction screening tools

All KYC data is securely stored and subject to strict access controls.

4. Source of Funds / Wealth (SoF / SoW)

VLKNA may request documents to verify the source of funds or source of wealth, particularly for:

High-velocity depositors

Large withdrawals exceeding monthly thresholds

Users with risk flags or behavioral inconsistencies

Acceptable documents include:

Recent pay slips or salary confirmations

Bank statements showing income streams

Tax declarations

Business ownership or dividend documentation

Cryptocurrency transaction histories and wallet origins

5. Transaction Monitoring

All transactions on the VLKNA platform (including deposits, withdrawals, and internal balance movements) are subject to real-time and retrospective monitoring.

Key monitoring triggers include:

Rapid deposit and withdrawal behavior (e.g. same-day cash-outs)

Round-number betting, arbitrage patterns, and risk-free wagers

Unusual cross-wallet or crypto activity

Gaming patterns inconsistent with normal player behavior

Transactions or user activity meeting suspicious criteria may result in:

Account flagging and temporary suspension

Delayed withdrawal processing

Formal investigation and audit

Filing of a Suspicious Activity Report (SAR) with competent authorities

6. AML Screening Tools and Third-Party Services

VLKNA partners with licensed and globally recognized providers to perform:

Sanctions list screening (e.g. OFAC, EU, UN, FATF)

PEP identification and risk categorization

Fraud and duplicate account detection

Crypto address tracing (if applicable)

All third-party providers are required to meet our data protection and compliance standards, and are contractually bound by confidentiality and usage limitations.

7. Reporting Obligations

If VLKNA reasonably suspects that a transaction or user is connected to money laundering or terrorist financing:

Internal escalation protocols are triggered immediately)

The case is reviewed by our Compliance and AML team

A Suspicious Activity Report (SAR) is filed with the designated authority in Anjouan or relevant offshore partner (as required)

The user may be permanently banned, and funds frozen pending resolution

VLKNA will not notify users when such reports are submitted, in line with "tipping-off" prevention laws.

8. Staff Training and Internal Controls

All VLKNA personnel involved in onboarding, support, or financial processing must:

Undergo AML/KYC training during onboarding and annually thereafter

Follow documented escalation protocols

Report suspicious activity or compliance gaps to senior management

Training is adapted to each role and updated to reflect the evolving regulatory landscape.

9. Record Keeping

All KYC documents, transaction logs, and internal compliance notes are retained for a minimum of 5 years from the date of account closure or final transaction, whichever is later. Records are stored in encrypted systems with restricted access and real-time audit trails.

10. Policy Review and Amendments

VLKNA may update this policy periodically to reflect changes in regulatory requirements, internal processes, or platform architecture. Updates will be posted to this page with a clearly indicated "Last Updated" date.

11. Contact and Compliance

General Inquiries: support@vlkna.com

Compliance and Investigations: compliance@vlkna.com