Anti-Money Laundering and KYC Policy

1.1. Grail Technologies Ltd ("Grailbet", "we") is committed to preventing money laundering, terrorist financing, sanctions evasion and fraud. This policy explains the measures we apply to all Customers of grailbet.com.

1.2. We operate under licence number ALSI-202512005-FI1 issued in the Autonomous Island of Anjouan, Union of Comoros, and apply a risk-based approach consistent with the Recommendations of the Financial Action Task Force (FATF).

2.1. We have appointed a Money Laundering Reporting Officer (MLRO) who is responsible for this policy, for reviewing suspicious activity, and for reporting to the relevant authorities.

2.2. All staff and contractors with access to customer data or payments receive AML training on joining and at least once a year.

2.3. This policy is reviewed at least once a year and whenever our products, payment methods or legal obligations change.

3.1. Every Customer must provide accurate registration details, including full name, date of birth, email address and country of residence. All Customers are screened against sanctions and PEP lists at registration and on an ongoing basis.

3.2. Full verification is required before a withdrawal can be processed where your deposit or withdrawal activity reaches the thresholds set in our internal risk framework, where our risk systems flag your account, or where your details do not match the information held by our payment or verification providers. We do not publish these thresholds.

3.3. Full verification consists of:

• a valid, unexpired government-issued photo ID (passport, national ID card or driving licence)
• a selfie and liveness check matched to the ID
• a proof of address dated within the last 3 months, such as a utility bill, bank statement or government letter

3.4. We may request verification at any time, regardless of the thresholds above.

3.5. Verification is carried out through our third-party identity verification provider. Most checks complete within minutes. Manual reviews are completed within 3 business days of receiving all documents.

4.1. We apply enhanced due diligence (EDD) where the risk is higher, including where:

• deposit or withdrawal volumes exceed the levels set in our internal risk framework
• you are a politically exposed person, a family member or a close associate of one
• you are linked to a high-risk jurisdiction
• activity on your account does not match your profile
• blockchain analytics link your wallet to high-risk sources

4.2. EDD may include proof of source of funds (for example payslips, bank statements, business accounts, sale of assets or exchange account statements showing the origin of cryptocurrency) and proof of source of wealth. We may also hold a video call with you.

4.3. We may suspend deposits, play and withdrawals on the account until EDD is complete.

5.1. All incoming and outgoing cryptocurrency transactions are screened using blockchain analytics. We do not accept funds from, or send funds to, wallets linked to sanctioned persons, darknet markets, mixers or tumblers, ransomware, scams or stolen funds.

5.2. Funds from a flagged source may be frozen pending review, returned to source where lawful, or reported to the authorities.

5.3. Withdrawals must be sent to a wallet you own or control. We may ask you to prove ownership of a wallet.

6.1. We monitor deposits, withdrawals and betting activity for unusual patterns, including:

• deposits followed by withdrawal with little or no play
• structuring of deposits to stay below verification thresholds
• use of multiple payment methods, wallets or accounts
• chip dumping or collusion between Customers
• betting patterns inconsistent with the Customer's known profile

6.2. Deposits must be wagered at least once before withdrawal. We do not allow the Service to be used as a payment or exchange service.

We do not accept Customers who:

• are under 18
• reside in or access the Service from a Restricted Territory listed in our Terms of Service
• are subject to sanctions, or are owned or controlled by a sanctioned person
• refuse to provide the information required under this policy
• provide false, forged or stolen documents
• act on behalf of another person

8.1. Staff must report any suspicion of money laundering or terrorist financing to the MLRO without delay.

8.2. The MLRO reports suspicious activity to the relevant financial intelligence unit and authorities as required by law.

8.3. We are prohibited by law from telling a Customer that a report has been made or that an investigation is ongoing.

Where a Customer fails verification, provides false information, or is found to be involved in money laundering, fraud or sanctions evasion, we may close the account, freeze or withhold funds, void bets, and share information with the authorities.

We keep customer identification records, transaction records and internal reports for at least 5 years after the end of the business relationship, or longer where required by law.

Questions about this policy can be sent to [email protected].