Anti-Money Laundering (AML) Policy

1. PURPOSE

This Anti-Money Laundering ("AML") Policy establishes the principles, procedures, and controls implemented by Diam.bet ("the Company," "we," "us," or "our") to prevent, detect, and report money laundering, terrorist financing, fraud, and other illicit financial activity.

The Company is committed to complying with all applicable AML laws, regulations, and industry best practices relevant to its business operations.

2. SCOPE

This policy applies to:

• All Company officers, owners, contractors, and employees
• All users of the Diam.bet platform
• All transactions processed through the platform, including Gold Coin purchases and prize redemptions

This policy covers customer onboarding, transaction monitoring, recordkeeping, and reporting obligations.

3. BUSINESS MODEL OVERVIEW

Diam.bet operates a sweepstakes gaming platform for entertainment. Key characteristics:

• No real-money wagering or gambling
• Gameplay uses virtual currencies: Gold Coins (entertainment only, no cash value) and Diam Coins (sweepstakes entries)
• No purchase necessary to play or win
• Gold Coin packages may be purchased by card or cryptocurrency; Diam Coins are included as a free bonus
• Eligible Diam Coins may be redeemed for prizes under the Official Sweepstakes Rules, subject to KYC and the controls in this policy

3.1 Restricted Jurisdictions

The sweepstakes promotion is void where prohibited or restricted by law, including for residents of Idaho and Washington. Any user found to be circumventing geographic restrictions or misrepresenting their location will have their account permanently banned and all balances forfeited.

4. AML RISK ASSESSMENT

The Company has assessed its AML risk based on:

• Customer profile and geographic location
• Transaction types (Gold Coin purchases and prize redemptions)
• Geographic exposure and restricted jurisdictions
• Payment and redemption methods (cards, bank transfers, gift cards, and cryptocurrency)

The Company considers its AML risk moderate and implements controls proportionate to its size, transaction volume, and operational structure. Where cryptocurrency is used for purchases or redemptions, the Company employs blockchain analytics and monitoring tools as appropriate.

5. CUSTOMER DUE DILIGENCE (KYC)

5.1 Account Registration

All users must:

• Be at least 18 years of age (or higher where required by law)
• Provide accurate registration information including country of residence
• Accept the platform's Terms of Service

5.2 Identity Verification (KYC)

Identity verification may be required before any prize redemption and may include:

• Government-issued photo ID
• Proof of address
• Email and phone verification
• Selfie verification / liveness check

The Company reserves the right to request additional documentation where necessary, including source of funds verification for large transactions.

5.3 Enhanced Due Diligence

Enhanced due diligence measures may be applied to users who:

• Conduct high-volume transactions
• Originate from higher-risk jurisdictions
• Exhibit unusual transaction patterns
• Are identified as Politically Exposed Persons (PEPs)

6. GEOGRAPHIC RESTRICTIONS & ENFORCEMENT

The Company enforces strict geographic access controls:

• Users must declare their country of residence during registration
• Users in jurisdictions where the sweepstakes is void are not eligible to participate
• Use of VPNs, proxies, or other methods to circumvent geographic restrictions is strictly prohibited

Enforcement: Any user found to have misrepresented their location or eligibility will have their account permanently banned. All balances will be forfeited. This policy applies equally to all restricted jurisdictions.

7. TRANSACTION MONITORING

The Company monitors user activity for suspicious behavior, including but not limited to:

• Unusual transaction volume or velocity
• Purchases followed by immediate redemption attempts with little or no gameplay
• Use of multiple accounts or wallet addresses
• Inconsistent user behavior patterns
• Attempts to bypass verification or geographic restrictions
• Structuring transactions to avoid reporting thresholds
• Transactions involving sanctioned wallet addresses

Automated and manual reviews are used to identify potentially suspicious activity. Blockchain analytics may be employed to trace cryptocurrency transaction origins.

8. SUSPICIOUS ACTIVITY HANDLING

If suspicious activity is detected, the Company may:

• Temporarily suspend the account pending investigation
• Conduct enhanced due diligence
• Request additional verification and source of funds documentation
• Decline or reverse transactions where permitted
• Permanently terminate the account
• Forfeit account balances where legally permissible

The Company cooperates fully with payment processors, financial institutions, and lawful authorities as required.

9. SANCTIONS & PEP SCREENING

The Company does not knowingly allow:

• Sanctioned individuals or entities
• Politically Exposed Persons (PEPs) without enhanced review
• Users listed on applicable sanctions lists (e.g., OFAC, EU, UN)
• Transactions involving sanctioned wallet addresses or jurisdictions

Screening is conducted as part of the KYC process where applicable.

10. CRYPTOCURRENCY PAYMENT CONTROLS

Where cryptocurrency is used for Gold Coin purchases or prize redemptions, additional controls include:

• Wallet address binding to verified user accounts
• On-chain transaction verification for purchases
• Manual review of flagged redemptions before payout
• Monitoring for transactions from mixing services or privacy-focused protocols
• Blockchain confirmation requirements before crediting purchases

11. RECORD KEEPING

The Company maintains records related to:

• Customer identification and verification documents
• Transaction activity including blockchain transaction hashes
• Wallet addresses associated with user accounts
• AML reviews and decisions

Records are retained for a minimum of five (5) years or as required by applicable law.

12. REPORTING OBLIGATIONS

Where required by law or contractual obligations, the Company will:

• Report suspicious activity to relevant authorities
• Respond to lawful requests for information
• Cooperate with payment processors, blockchain analytics firms, and regulators

13. TRAINING & AWARENESS

Personnel responsible for compliance receive training appropriate to their role, including:

• Identifying suspicious activity and cryptocurrency-specific red flags
• Escalation procedures
• AML responsibilities and regulatory requirements

14. GOVERNANCE & RESPONSIBILITY

The Company has designated a responsible individual to oversee AML compliance.

AML Compliance Contact:
Email: [email protected]

15. POLICY REVIEW

This AML Policy is reviewed periodically and updated as necessary to reflect:

• Changes in laws or regulations
• Changes in business operations
• Developments in cryptocurrency regulation
• Processor or banking requirements

16. CONFIDENTIALITY

This policy is an internal compliance document and may be shared with payment processors, banking partners, and regulators for verification purposes.