Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy – bet90review.com 🔒

Last updated: 25 October 2025

This page sets out the official Anti-Money Laundering (AML)r Customer (KYC) framework for Bet90Review (bet90review.com).
The policy is designed to protect users and partners, deter illicit finance, and align any
payment-related activities with internationally recognized standards.

It is written to meet EEATertise, Authoritativeness, Trustworthiness)
and YMYL (Your Money or Your Life) expectations by providing clear definitions,
robust controls, and verifiable procedures. ✅

📌 Scope, Purpose, and Applicability

Bet90Review is primarily an educational and informational websiteML/KYC Policy
applies to any and all current or future payment-related processes operated under
bet90review.com, including (where applicable):

• Account registration and user profile management for premium or paid features
• Deposits, withdrawals, refunds, and subscription payments (if offered)
• User-to-user transfers, wallet credits, or internal balance movements
• Promotional credits or bonuses that may be converted into monetary value
• Dispute resolution involving financial transactions

This Policy applies to:

• All staff and senior management involved in Bet90Review operations
• Contractors, consultants, and outsourced service providers supporting our services
• Payment partners, PSPs, and financial intermediaries we may cooperate with
• Customer support, risk, and compliance functions linked to bet90review.com

🧭 Regulatory Alignment & Best-Practice References

Our AML/KYC framework is informed by globally recognized standards and applicable laws, including:

• FATF Recommendations – risk-based AML/CFT approach, CDD/EDD, ongoing monitoring,
  reporting, and record retention.
• Directive (EU) 2015/849 and Directive (EU) 2018/843
  (AMLD4 / AMLD5) regarding AML/CFT obligations.
• Regulation (EU) 2015/847 on information accompanying transfers of funds.
• Applicable national AML/CFT and sanctions laws relevant to users’ locations and to our
  payment partners or processors.
• Data protection principles consistent with GDPR for privacy, security, lawfulness,
  and data minimization.

🧾 Key Definitions

• Money Laundering (ML): Converting, transferring, concealing, or disguising the origin of
  property known or suspected to be derived from criminal activity, or assisting persons involved in such activity
  to evade legal consequences.
• Customer Due Diligence (CDD / KYC): Identifying and verifying customers, understanding the
  purpose and intended nature of the relationship, and applying ongoing monitoring.
• Enhanced Due Diligence (EDD): Additional checks for high-risk customers, jurisdictions,
  products, channels, or behaviors.
• Source of Funds (SoF) / Source of Wealth (SoW): Evidence explaining the origin and legitimacy
  of deposited funds and a user’s overall wealth.
• Suspicious Transaction/Activity Report (STR/SAR): A formal report submitted to a
  Financial Intelligence Unit (FIU) when ML/TF is suspected.

🏛️ Governance & Accountability

AML/KYC responsibilities at Bet90Review are structured as follows:

• Senior Management – sets the tone from the top, approves this Policy, allocates resources,
  and oversees effectiveness.
• AML Compliance Officer (AMLCO) – designs and maintains controls, supervises monitoring,
  investigates alerts, escalates cases, and liaises with competent authorities where applicable.
• First Line (Operations & Support) – executes CDD/EDD procedures, enforces payment rules,
  and flags anomalies.
• Internal Audit / Independent Review – performs periodic checks, tests controls, and provides
  recommendations for continuous improvement.

🛠️ Policy Maintenance & Change Control

• This AML/KYC Policy is reviewed at least annually or when material regulatory or business changes occur.
• Material updates undergo a documented risk impact assessment.
• Updates must be approved by Senior Management and the AMLCO.
• Previous versions are archived to preserve an auditable history of changes.

🧩 Risk-Based Approach (RBA) & Enterprise-Wide Risk Assessment (EWRA)

Bet90Review applies a Risk-Based Approach (RBA)r> Enterprise-Wide Risk Assessment (EWRA) is conducted at least annually to evaluate inherent risks across:

• Products and services (e.g., premium content, subscriptions, or other paid features)
• Delivery channels and payment methods
• User types and behavioral segments
• Geographical footprint and jurisdictional risk
• Transactional patterns and value ranges
• Sanctions exposure, PEP risk, and high-risk sectors
• Emerging ML/TF typologies, including online and digital risks

EWRA outcomes define thresholds, EDD triggers, rules, and monitoring frequency, and guide
resource allocation for compliance functions.

🪪 Tiered Customer Verification (KYC)

Where Bet90Review offers payment-enabled features, user verification follows a tiered structure.
Certain actions (especially withdrawals or higher-risk operations) may be paused until the required tier is
successfully completed.

Tier 1 – Basic Profile (required before any withdrawal)

• Full name, date of birth, gender, nationality
• Country of usual residence and full residential address
• Automated database checks (sanctions, watchlists, PEP, where applicable)
• If automated or database checks are unavailable or show mismatches, a basic proof of address
  may be requested.

Tier 2 – Advanced ID Verification

Triggered when cumulative deposits or withdrawals reach
2,000 (USD/EUR or equivalent).

• Valid government-issued photo ID, photographed next to a random 6-digit code written by the user.
• A live selfie to verify biometric match with the ID.
• If e-verification is not possible or fails, a recent proof of address (utility bill,
  bank statement, or official letter issued within the last 3 months) showing full name and address is required.
• Documents must be fully visible (all four corners) and readable.

Tier 3 – Source of Funds / Source of Wealth (SoF/SoW)

Triggered when:

• Cumulative deposits/withdrawals reach 5,000 (USD/EUR or equivalent), or
• Peer-to-peer transfers reach 3,000 (if such functionality exists).

Acceptable SoF/SoW evidence includes (non-exhaustive):

• Employment income: recent payslips, employer/HR letters, tax statements.
• Business ownership: audited accounts, tax filings, corporate registry extracts.
• Investments: brokerage statements, dividend records, proof of asset liquidation.
• Inheritance or gifts: probate documents, notarized deeds, bank confirmations.
• Sale of assets: contracts of sale, notarial records, bank slips showing proceeds.

🌍 Geographic Risk Categorization

Bet90Review considers geographic risk based on sanctions, AML/CFT effectiveness, and regulatory advisories:

• Low Risk: Standard thresholds as described above.
• Medium Risk: Lower thresholds (e.g., Tier 2 at 1,000; Tier 3 at 2,500);
  additional monitoring and restrictions on certain payment types (e.g., crypto on/off-ramp via partners).
• High Risk: Service may be restricted or prohibited. Jurisdiction lists are reviewed against
  sanctions lists and regulatory advisories from relevant authorities.

💳 Payment Method Controls

• The same method used for deposit should be used for withdrawal at least up to
  the deposited amount, to reduce ML risks.
• Third-party payment instruments are prohibited. The name on the payment method must match the
  verified user name.
• Intentional structuring of deposits/withdrawals to stay below verification thresholds may trigger EDD,
  restrictions, or account closure.

🔎 Ongoing Monitoring & Three Lines of Control

First Line

Operations and support teams, together with our payment partners, apply real-time controls during
onboarding and at transaction time, based on PSP and banking AML standards.

Second Line

The AMLCO oversees rules-based and, where available, machine-assisted monitoring. Red flags may include:

• Rapid deposit and withdrawal cycles with minimal genuine platform usage
• Behavior inconsistent with declared profile (e.g., sudden large payments)
• Frequent currency switching or unusual patterns via allowed channels
• Account takeover indicators, device changes, IP anomalies
• Counterparties or payment sources from high-risk jurisdictions

Third Line

High-risk or suspicious users are subjected to manual case reviewsby law,
STR/SAR filings are submitted to the competent FIU.

📈 Control Thresholds at a Glance

🚨 Detection, Escalation, and STR/SAR

• Staff must promptly escalate atypical or suspicious activity to the AML function via secure
  internal channels.
• The AML team evaluates alerts, documents the rationale, and determines whether an STR/SAR is required.
• “Tipping-off” is strictly prohibited; users will not be informed of STR/SAR submissions where
  law prevents such disclosure.

🧰 Procedures & Playbooks

Operational playbooks translate this Policy into step-by-step procedures, covering:

• Minimum CDD standards for onboarding
• Sanctions and watchlist screening workflows
• EDD triggers, case escalation, and decision-making
• Rules for account restrictions, blocks, or closure
• Communication templates balancing transparency and AML obligations

As an additional safeguard, first withdrawals may require meaningful transactional activity
(e.g., at least 70% of deposited funds used in a genuine, non-circular way), to deter pure pass-through flows.

🧾 Record-Keeping

• KYC records are retained for at least 10 years after the business relationship ends,
  or longer where legally required.
• Transaction records are retained for at least 10 years after execution or termination,
  whichever is later.
• Records are stored securely with encryption at rest and in transit, using both online
  and offline safeguards, and access is strictly role-based.

🧑‍🏫 Training & Awareness

• Mandatory AML/KYC induction training is provided to all new hires whose roles touch financial or user data.
• Periodic refresher training is provided for finance, risk, operations, and support teams.
• Case-based learning addresses typologies such as smurfing, mule accounts, synthetic identities,
  and crypto on/off-ramp risks (where relevant).
• Training effectiveness is monitored through KPIs, quality checks, and audit findings.

🧪 Internal Audit & Continuous Improvement

Internal or independent audits periodically review:

• Design and effectiveness of AML controls
• Data quality and completeness of KYC and transaction records
• Timeliness and quality of case handling and escalations

Metrics such as false-positive ratios, case turnaround time, and post-investigation outcomes
are used to drive continuous improvement plans.

🧱 Data Protection & Privacy 🔐

• Bet90Review collects the minimum data necessary for lawful AML/KYC purposes and for
  providing its services. Data are not sold to third parties.
• Information may be shared only when required by law, by court order, or for the prevention/detection of
  financial crime with appropriate safeguards.
• We respect data subject rights under applicable privacy laws, including rights of access, rectification,
  restriction, and objection, subject to AML retention obligations.

🚫 Zero-Tolerance for Violations

• Accounts linked to forged documents, stolen payment instruments, account takeover, or unjustified flows
  may be restricted, frozen, or terminated.
• Confirmed ML/TF or fraud activity is reported to competent authorities without prior user notice,
  where permitted or required by law.
• Failure to cooperate with AML/KYC requests may result in delayed withdrawals, rejected transactions,
  or account restrictions.

📫 Contact

If you have questions about this AML/KYC Policy, wish to exercise applicable privacy rights,
or need to report suspicious activity related to Bet90Review, please use the contact details below:

• Website: bet90review.com
• Email – Support: [email protected]
• Email – General: [email protected]
• Email – Complaints / AML reports: [email protected]
• Phone (sample support line):
  +98 21 4829 9030
• Registered support office address:
  Tehran, Gandhi North Street, 22nd Alley, No. 12, 3rd Floor, Unit 7, Iran

⚠️ Compliance Notice

Use of bet90review.com and any related payment-enabled features (if and when offered)
constitutes acceptance of this AML/KYC Policy.

Failure to provide requested documentation, submit accurate information, or pass verification checks may result in:

• Delayed or rejected withdrawals
• Declined or reversed transactions
• Temporary or permanent account restrictions

Bet90Review reserves the right to update this document to reflect evolving regulations, supervisory expectations,
and industry best practices. The latest version will always be published on this page.