Anti-money laundering policy

1. Policy overview

As a provider of iGaming technology, Platform1 operates in a regulated environment where anti-money-laundering (AML) and counter-terrorist-financing (CTF) compliance is essential. This policy sets out our commitment to detecting, preventing and reporting activity that may indicate money laundering or terrorist financing.

Our role. Platform1 is a B2B technology provider. We contract with licensed operators and their companies; we do not accept deposits from or pay winnings to players. AML obligations towards players rest with the operator under its gaming licence. Platform1 (a) applies due diligence to its own clients as described below, and (b) provides the KYC, monitoring and reporting tooling that operators need to meet their obligations.

• Zero tolerance: we do not tolerate money laundering or terrorist financing and terminate relationships where it is suspected.
• Compliance: we comply with applicable Estonian and EU regulations.
• Monitoring: we monitor client relationships and payment flows to Platform1 on an ongoing basis.
• Training: everyone at Platform1 who deals with clients receives AML training and regular updates.

2. Regulatory framework

• Estonian Money Laundering and Terrorist Financing Prevention Act (MLTFPA): the primary Estonian legislation governing AML/CTF obligations for companies and service providers.
• EU Anti-Money Laundering Directives (4AMLD, 5AMLD, 6AMLD): the European Union framework for AML/CTF across member states.
• Financial Action Task Force (FATF) recommendations: the international standards for combating money laundering and the financing of terrorism and proliferation.
• Gaming regulators’ requirements: the AML conditions imposed by the regulators our clients are licensed by, such as the Curaçao Gaming Control Board, the Malta Gaming Authority, the UK Gambling Commission and EU/EEA national regulators. The platform’s tooling is designed to support those conditions; the licence and the obligation remain the operator’s.

3. Customer due diligence (CDD)

We apply due diligence procedures to verify the identity of our clients and assess their risk profile before and during a business relationship.

Standard due diligence (all clients)

When applied: for every new business relationship and for transactions with Platform1 above €1,000.

• Identity verification of the signatory using government-issued documents
• Proof of address
• Business registration documents for the contracting company
• Source-of-funds declaration
• Identification of beneficial owners
• Confirmation of the gaming licence or licensed partner under which the brand will operate

Enhanced due diligence (high risk)

When applied: for high-risk clients, politically exposed persons (PEPs), complex ownership structures, or transactions above €15,000.

• Enhanced identity verification and background checks
• Source-of-wealth documentation
• Ongoing monitoring of the business relationship
• Senior management approval of the relationship
• Regular review of the risk assessment

Simplified due diligence (low risk)

When applied: for low-risk clients from low-risk jurisdictions with transparent ownership.

• Basic identity verification
• Simplified documentation requirements
• Reduced ongoing monitoring
• Risk-based timing of verification

4. Risk assessment framework

We assess each client relationship against the following risk factors and review the assessment periodically.

Geographic risk

• High: countries on the FATF black or grey lists, or with inadequate AML/CTF systems.
• Medium: countries under increased FATF monitoring or with identified deficiencies.
• Low: EU/EEA countries and other jurisdictions with robust AML/CTF frameworks.

Customer risk

• High: PEPs, sanctioned individuals, cash-intensive businesses, offshore entities with opaque ownership.
• Medium: high-value transactions, unusual business activity, complex ownership structures.
• Low: established businesses with transparent ownership and reasonable transaction patterns.

Product and service risk

• High: anonymous or cash-based payment flows, services to unlicensed operators.
• Medium: cryptocurrency settlement, high-value gaming, cross-border services.
• Low: standard platform services to licensed operators in regulated markets with transparent payment methods.

Transaction risk

• High: transactions above €15,000, unusual patterns, frequent large payments.
• Medium: transactions between €1,000 and €15,000, occasional large transactions.
• Low: transactions under €1,000 with consistent patterns.

5. Prohibited activities

Platform1 prohibits the following and terminates business relationships where such activity is suspected:

• Money laundering: any attempt to disguise the origin of illicit funds through platforms or services we provide, including layering funds through gaming transactions, using gaming accounts for fund transfers, or converting criminal proceeds into gaming credits.
• Terrorist financing: providing financial support or services to terrorist organisations or activities, including transactions involving sanctioned individuals or entities and services for persons on terrorism watch lists.
• Sanctions evasion: circumventing international sanctions or embargoes, including services to sanctioned countries or regions and transactions involving blocked persons.
• Structuring: breaking large transactions into smaller ones to avoid reporting thresholds, coordinating activity across multiple accounts, or deliberately avoiding due-diligence procedures.

6. Transaction monitoring and reporting

Platform tooling for operators

The platform gives operators rule-based transaction monitoring with real-time screening, pattern and anomaly flags, risk scoring and alerts, KYC-provider integrations with document and liveness checks, PEP and sanctions screening, and case notes suitable for suspicious activity reports. Thresholds and rules are configured per licence by the operator.

Platform1’s own monitoring

Payments to Platform1 and the conduct of client relationships are reviewed by a named person. Triggers for manual review include payments above €10,000, unusual payment patterns, high-risk client activity and payments from third parties or unexpected jurisdictions.

Suspicious activity reporting

Authority: the Estonian Financial Intelligence Unit (FIU).

• Suspicious transactions are reported without delay and in any case within the statutory deadline
• Suspicions of terrorist financing are reported immediately
• Supporting documentation is retained for 5 years

Thresholds

• Enhanced due diligence: transactions above €15,000 or high-risk indicators
• Manual review: payments above €10,000
• Suspicious activity: any amount, reported to the FIU
• Terrorist financing: any amount, reported immediately

7. Record keeping

Client records (5 years after the relationship ends)

• Identity verification documents
• Proof of address
• Business registration certificates
• Beneficial ownership information
• Risk assessment documentation

Transaction records (5 years after the transaction)

• Transaction details and amounts
• Payment method information
• Source and destination of funds
• Purpose of the transaction
• Monitoring and review notes

Compliance records (5 years minimum)

• Suspicious activity reports
• Training records
• Policy updates and approvals
• Audit reports and findings
• Regulatory correspondence

8. Training and awareness

Initial training (within 30 days of joining)

• AML/CTF legal requirements
• Company policies and procedures
• Risk identification and red flags
• Reporting procedures and requirements
• Customer due diligence procedures

Ongoing training (annual refresher plus ad-hoc updates)

• Regulatory updates and changes
• New typologies and threats
• Case studies and examples
• System updates and procedures
• Assessment and testing

Specialised training (compliance lead and management)

• Risk assessment techniques
• Investigation procedures
• Regulatory liaison and reporting
• Industry practice
• Technology and system management

9. Contact and reporting

• Compliance contact: [email protected] (subject line "AML")
• Address: Platform1 OÜ, Tallinn, Estonia
• Estonian Financial Intelligence Unit: fiu.ee, electronic reporting through goAML

Confidential reporting. Employees, clients and third parties can report suspected money laundering, terrorist financing or sanctions violations by email to the compliance contact with the subject line "Confidential AML report". Reports are handled confidentially, investigated, and the identity of the reporter is protected to the fullest extent the law allows. Anonymous reports are accepted.

Version history: 15 January 2025, initial version. 11 October 2026: Platform1’s role as a technology provider clarified; monitoring section split into platform tooling and Platform1’s own procedures; contact addresses consolidated.