“KNOW YOUR CLIENT” POLICY

Last updated: March 2026

The Company adheres to and fully complies with "Know Your Customer" ("KYC") principles, which aim to prevent financial crime and money laundering through client identification and due diligence, in accordance with the Computer Gaming Licensing Act 007 of 2005 and the Money Laundering Prevention Act 008 of 2005 of the State of Anjouan, Union of Comoros, and any directives or guidelines issued by the Anjouan Offshore Financial Authority ("AOFA") and Anjouan Licensing Services Inc. ("ALSI").

The Company reserves the right, at any time, to ask for any KYC documentation it deems necessary to determine the identity and location of a Customer. The Company may also employ third-party verification services to assist in confirming the identity and bona fides of Customers. We reserve the right to restrict the service, payment, or withdrawal until identity is sufficiently determined or for any other reason in accordance with our regulatory obligations.

We take a risk-based approach and perform strict due diligence checks and ongoing monitoring of all clients, customers, and transactions. As per the money laundering regulations applicable in the State of Anjouan and international best practices, we utilise three stages of KYC due diligence, as follows:

SDD — Simplified Due Diligence is used in instances of extremely low-risk transactions that do not meet the required thresholds and where the risk of money laundering or terrorist financing has been assessed as low.

CDD — Customer Due Diligence is the standard level of due diligence checks, used in most cases for verification and identification of customers. CDD is applied at the point of account registration and whenever regulatory thresholds are triggered.

EDD — Enhanced Due Diligence is used for high-risk customers, large transactions, politically exposed persons ("PEPs"), customers from higher-risk jurisdictions, or any other special cases where the risk of money laundering or terrorist financing is assessed as elevated.

Separately and in addition to the above, when a user makes an aggregate lifetime total of deposits exceeding EUR 10,000 or requests a withdrawal of any amount inside the www.wildies.com, or attempts to or completes a transaction that is deemed suspicious by our compliance team, then it is compulsory for them to complete the full KYC process. This threshold has been determined on the basis of a documented risk-based assessment, taking into account the nature and risk profile of the Company's customer base.

Additionally, the Company shall require completion of the KYC process in the following circumstances:

  • When there is a suspicion of money laundering or terrorist financing;
  • When there is a doubt about the veracity or adequacy of previously obtained customer identification data;
  • When a customer's transaction patterns change significantly or are inconsistent with their profile;
  • When a customer is identified as a Politically Exposed Person ("PEP") or becomes a PEP;
  • At any point deemed necessary by the Company's Compliance Officer in the exercise of their professional judgement.

During this process, the user will have to input some basic details about themselves and then upload the following documents:

  • A copy of a Government-Issued Photo ID (in some cases front and back depending on the ID document) - e.g. passport, national identity card, or driving licence;
  • A selfie of themselves holding the ID document (for biometric verification purposes);
  • A bank statement or utility bill (as proof of residential address, dated within the last three (3) months).

Guideline for the "KYC Process"

Proof of ID

Signature is present on the document (where applicable)

Country of issuance is not one of the following Restricted Countries:

Australia

Austria

France and its territories

Germany

Netherlands and its territories

Spain

Union of Comoros

United Kingdom

USA and its territories

All FATF Blacklisted countries

Any other jurisdictions deemed prohibited by the Anjouan Offshore Financial Authority.

Full name matches the client's registered name on the Account;

Document does not expire within the next 3 months;

Holder is over 18 years of age (or the applicable legal age for gambling in their jurisdiction);

Proof of Residence

Bank Statement or Utility Bill

Country of residence is not one of the following Restricted Countries:

Australia

Austria

France and its territories

Germany

Netherlands and its territories

Spain

Union of Comoros

United Kingdom

USA and its territories

All FATF Blacklisted countries

Any other jurisdictions deemed prohibited by the Anjouan Offshore Financial Authority.

Full name matches the client's name and is consistent with the name on the Proof of ID.

Date of Issue: Within the last 3 months

Selfie with ID

Holder is the same person as depicted in the ID document above

ID document visible in the selfie is the same as in the Proof of ID. The photo and ID number must match.

Enhanced Due Diligence ("EDD")

In addition to the standard KYC checks set out above, Enhanced Due Diligence shall be applied on a risk-sensitive and proportionate basis in the following circumstances:

  • The customer is identified as a Politically Exposed Person ("PEP"), or a family member or close associate of a PEP. Identification as a PEP does not automatically preclude the establishment of a business relationship, but requires the application of appropriate EDD measures;
  • The customer is from a jurisdiction identified as high-risk by the FATF, the EU, or by the Anjouan Offshore Financial Authority;
  • The customer's transaction patterns are unusual, inconsistent with their profile, or exceed defined thresholds;
  • There are grounds for suspicion of money laundering, terrorist financing, or any other financial crime;
  • The customer has been subject to adverse media reports or has been identified on any international sanctions list.

EDD measures may include, but are not limited to:

  • Obtaining additional documentation verifying the source of funds and source of wealth;
  • Conducting enhanced background checks using third-party databases and open-source intelligence;
  • Requiring senior management approval for establishing or continuing the business relationship;
  • Conducting more frequent and intensive ongoing monitoring of the customer's account and transactions;
  • Restricting the customer's account or transaction limits pending satisfactory completion of EDD.

Ongoing Monitoring

The Company conducts ongoing monitoring of all customer accounts and transactions to identify and report suspicious activity. Ongoing monitoring includes, but is not limited to:

  • Monitoring transaction patterns for unusual activity, including deposits, withdrawals, and betting patterns that are inconsistent with the customer's profile;
  • Periodic review and update of customer identification information and documentation;
  • Screening of customers against applicable sanctions lists, PEP databases, and adverse media on an ongoing basis;
  • Automated transaction monitoring systems designed to flag potentially suspicious transactions for manual review by the compliance team.

Where suspicious activity is detected, the Company shall:

  • Conduct a thorough internal investigation;
  • File a Suspicious Activity Report ("SAR") or Suspicious Transaction Report ("STR") with the relevant authorities, as required under the Money Laundering Prevention Act 008 of 2005;
  • Take appropriate action, which may include restricting, suspending, or closing the customer's account;
  • Refrain from tipping off the customer about the filing of any SAR/STR or any ongoing investigation.

Record Keeping

The Company shall maintain records of all KYC documentation, customer identification data, and transaction records for a minimum period of five (5) years from the date of the transaction or the date the business relationship ends, whichever is later, or for such longer period as may be required by applicable law or by direction of the Anjouan Offshore Financial Authority.

Records shall include:

  • Copies of all identification documents obtained during the KYC process;
  • Records of all transactions carried out through the customer's account;
  • Records of all internal assessments, risk ratings, and due diligence decisions;
  • Copies of all SARs/STRs filed with the relevant authorities;
  • Records of all staff training undertaken in relation to AML/CFT and KYC compliance.

Staff Training

All staff members involved in customer-facing roles, compliance, and management shall receive regular training on KYC and AML/CFT obligations. Training shall cover:

  • The Company's KYC and AML/CFT policies and procedures;
  • Identification and reporting of suspicious transactions;
  • Applicable legal and regulatory requirements, including the Money Laundering Prevention Act 008 of 2005 and any directives issued by AOFA;
  • Recognising indicators of money laundering, terrorist financing, and fraud;
  • Data protection and confidentiality obligations in relation to customer data.

Training shall be conducted at least annually and records of all training shall be maintained by the Company.

Compliance Officer

The Company shall appoint a designated Compliance Officer who shall be responsible for:

  • Overseeing the implementation and effectiveness of the Company's KYC and AML/CFT policies;
  • Reviewing and approving all EDD assessments and high-risk customer relationships;
  • Ensuring timely filing of SARs/STRs with the relevant authorities;
  • Liaising with the Anjouan Offshore Financial Authority and other regulatory bodies as required;
  • Reporting to senior management on the Company's AML/CFT compliance status;
  • Ensuring that all staff receive adequate and regular training on KYC and AML/CFT matters.

Notes on the "KYC Process"

When the KYC process is unsuccessful then the reason is documented and a support ticket is created in the system. The ticket number along with an explanation is communicated back to the user.

Once all proper documents are in our possession and have been verified by our compliance team, the account gets approved.

Where the Company is unable to complete the KYC process satisfactorily, the business relationship shall not be established or shall be terminated, and any funds held shall be returned to the customer via the original payment method, subject to applicable regulatory requirements.

The Company shall not establish or continue a business relationship where it suspects money laundering or terrorist financing, and shall file a SAR/STR with the relevant authorities.

Wildies