AML & KYC Policy

1. Introduction & Commitment

frogbet ("the Company") is committed to the highest standards of Anti-Money Laundering (AML) compliance and counter-terrorist financing (CTF) controls. This policy applies to all employees, contractors, and third-party service providers acting on behalf of the Company.

The Company operates under a valid gaming licence and is obligated to comply with all applicable AML legislation, regulations, and guidance issued by competent authorities. Failure to comply with these obligations may result in criminal and regulatory sanctions, reputational damage, and harm to the wider public.

2. Know Your Customer (KYC)

The Company applies a risk-based approach to customer due diligence (CDD). Standard accounts may operate below defined thresholds without formal identity verification. Enhanced due diligence (EDD) is required for high-risk customers, politically exposed persons (PEPs), and transactions exceeding our threshold limits.

When triggered, KYC documentation may include a valid government-issued photo ID (passport or national identity card), proof of address dated within the last three months (utility bill or bank statement), and — for large transactions — source-of-funds documentation demonstrating the legitimate origin of deposited funds.

3. Risk Assessment

The Company maintains a written enterprise-wide risk assessment that is reviewed at least annually and updated following material changes to the business, the regulatory environment, or threat landscape. Risk factors assessed include customer risk, geographic risk, product/service risk, and delivery channel risk.

Customers are scored on an ongoing basis. Accounts exhibiting unusual patterns — such as large deposits followed immediately by full withdrawal without meaningful gameplay, structuring behaviour, or use of multiple payment methods inconsistent with customer profile — are flagged for review.

4. Transaction Monitoring

All customer transactions are monitored in real time using automated screening tools calibrated to our risk appetite. Alerts are generated for transactions and behaviours that deviate from a customer's established profile or exceed defined thresholds.

The Company's Compliance Officer reviews triggered alerts and determines whether a Suspicious Activity Report (SAR) should be filed with the relevant Financial Intelligence Unit. All SAR filings are confidential and must not be disclosed ("tipped off") to the customer or any third party.

5. Record Keeping

The Company retains all KYC documentation, transaction records, and AML investigation files for a minimum of five (5) years from the end of the business relationship or the date of an occasional transaction. Records are stored securely and made available to competent authorities upon lawful request.

6. Training & Accountability

All relevant staff receive AML/CTF training upon joining the Company and at regular intervals thereafter. Training covers recognition of suspicious activity, the Company's reporting procedures, and the legal consequences of facilitating money laundering or terrorist financing.

The nominated Compliance Officer bears primary responsibility for the day-to-day operation of this policy and reports directly to senior management. Employees who identify potential money laundering activity must report it internally to the Compliance Officer immediately.

7. Policy Review

This AML & KYC Policy is reviewed at least annually by the Compliance Officer and approved by senior management. Material regulatory changes may trigger an ad-hoc review outside of the annual cycle. Questions regarding this policy should be directed to compliance@frogbet.com.