Introduction and Purpose

Globalbet maintains this Anti-Money Laundering Policy to comply with applicable AML laws and to prevent the use of its platform for money laundering, terrorist financing, or other illicit activity. This Policy establishes the governance, controls, and procedures used to identify, assess, monitor, and mitigate AML risk across all products and markets where Globalbet operates.

Governing Framework and Program Components

Globalbet adopts a risk‑based AML program that is designed to detect and report suspicious activity, preserve information for investigations, and cooperate with competent authorities. The program comprises the following core elements:

• Know Your Customer and Customer Due Diligence (KYC/CDD) procedures
• Ongoing monitoring of customer behavior and payment risk indicators
• Mitigation of risks through robust payout and payment controls
• Designation of an AML Officer (MLRO) with defined governance responsibilities
• Employee training on AML risks, procedures, and reporting obligations
• Periodic reassessment and updating of policies to reflect changes in risk, products, or technology

Customer Onboarding and Verification

On onboarding, Globalbet requires all mandatory information to be provided and verified. The information collected includes the user’s full name, date of birth, residential address, contact details, valid email address, and relevant payment information. Globalbet reserves the right to suspend or close an account if information proves false or cannot be verified.

Account Ownership and Access

Users may hold only one Member Account. Attempts to open additional accounts will result in blockage or closure of all accounts, with bets and winnings from closed or blocked accounts voided at Globalbet’s discretion.

Verification Triggers and Documentation

Standard Verification is triggered when the user’s transactions total USD 1,000 or more, or when the risk assessment identifies significant AML concerns. Verification requires submission of:

• A government issued identity document with a clear photo
• A photograph of the payment method used for deposits, showing the cardholder name; card numbers may be masked as permitted by law
• Proof of address showing the user’s name and current residential address (e.g., utility bill or bank statement)
• Additional live verification steps as required, including a photograph of the user holding the required documents

Globalbet may require further documentation or information to complete verification, and to verify address and identity beyond onboarding as risk dictates.

Risk Assessment and Customer Categorization

Globalbet employs a risk‑based framework to categorize customers. Key risk factors include country of residence, payment method, IP address, device fingerprints, and observed transaction patterns. Higher risk indicators may lead to enhanced monitoring, temporary deposit restrictions, or additional verification steps until risk is mitigated.

Enhanced Due Diligence for High Risk Players and PEPs

For customers identified as Politically Exposed Persons (PEPs) or originating from high risk jurisdictions, Globalbet applies Enhanced Due Diligence. This may require additional documentation, confirmation of source of wealth and funds, and, where necessary, senior management approval before allowing ongoing activity. The customer may be asked to provide information such as employment details, tax residency, and banking relationships, and funds source confirmation may be requested directly from the customer.

Transaction Monitoring and Payment Controls

Globalbet enforces strict controls to ensure that payments are linked to verified ownership of funds. Rules include:

• The name on any payment card used for deposits or withdrawals must match the account holder’s name.
• For electronic wallets, the registered email must match the account email.
• Deposits from third parties are prohibited; withdrawals must be to an instrument owned by the user and verifiable as such.
• Anonymous payments and cryptocurrency funds are not accepted for deposits or withdrawals.

All payments are subject to ongoing verification and scrutiny. If a payment instrument cannot be readily verified, Globalbet may require additional evidence before funds are released.

Ongoing Monitoring and Suspicious Activity

All user activity and financial transactions are continuously monitored for indicators of money laundering, terrorist financing, or other illicit activity. Indicators include, but are not limited to, excessive depositing, use of multiple devices or IP addresses, rapid changes in payment methods, or abrupt changes in account behavior. Any suspicious activity is escalated to the anti‑fraud and AML teams for assessment, with possible limitations, account suspension, or involvement of regulators where warranted.

Record Keeping and Data Protection

Globalbet retains all verification documents, identification data, transaction records, and supporting evidence in accordance with applicable AML and data protection laws. Retention periods align with regulatory requirements, typically extending for a minimum of seven years from the date of last activity or as required by law. Personal data processing complies with applicable data protection legislation and Globalbet’s Privacy Notice, with access restricted to authorized personnel.

Cooperation with Authorities and Policy Amendments

Globalbet will cooperate with competent regulatory and law enforcement authorities in AML/CFT investigations, including providing information as required by law. This Policy may be amended from time to time at Globalbet’s sole discretion. Material changes will be communicated to affected users via the contact email on file. Continued use of Globalbet’s services after notification constitutes acceptance of the amended Policy.