Donbet maintains an anti-money laundering (AML) and counter-terrorism financing (CTF) program designed to prevent the use of its platform for illicit purposes. The program applies a risk-based approach to customer due diligence, transaction monitoring, and reporting in compliance with applicable law and regulatory expectations.
This policy applies to all Donbet customers, employees, contractors, and agents, and governs all channels and jurisdictions in which Donbet operates. It covers onboarding, ongoing activity, and any account remediation actions.
Donbet appoints a Money Laundering Reporting Officer (MLRO) with overall responsibility for the AML program. The MLRO oversees policies, controls, training, and escalation of suspicious activity. All staff must complete AML awareness training at onboarding and on an annual basis or as required by changes in law. The Compliance function maintains access to transaction monitoring data and is responsible for timely escalation to authorities where required.
Donbet undertakes reasonable steps to verify customer identity before granting ongoing access to services. Onboarding requires collection of: full legal name; date of birth; residential address; contact details; valid email and phone number; and payment method details enabling source of funds validation. Donbet prohibits accounts opened under fictitious or anonymous identifiers and requires documentation to verify the information provided. Verification documents may include a government-issued identity document and a proof of address no older than three months. The minimum data and documents listed above must be requested and reviewed prior to permitting payouts exceeding USD 2,000 in a single transaction or where there is a material change in risk. Verification may be supplemented using independent data sources, including public records and sanctions screening services. Any uncertainty about information must be escalated to the MLRO for further action.
All customer activity is subject to continuous monitoring. Donbet utilizes automated and manual review processes to detect suspicious patterns. The system flags transactions above USD 1,000 or otherwise atypical for review. Red flags include: transactions from high-risk regions without a clear business purpose; rapid deposits followed by immediate withdrawals; unusual or unexplained transaction patterns; inconsistent or unverifiable customer information; or frequent changes in payment methods. When a red flag is identified, the MLRO and Transaction Monitoring Department assess whether further information is required, conduct internal or external inquiries, and determine appropriate action including hold, further verification, or reporting to authorities.
Donbet prohibits cash and non-electronic payments from players. Funds may be received by credit or debit cards, electronic transfers, or other compliant means approved by regulators. Where possible, winnings or refunds will be transferred by the same route used to originate the funds. Transfers between Donbet accounts or to third parties are prohibited unless explicitly authorized by policy and regulatory requirements. All transfers and related records shall be maintained in a manner that ensures traceability and compliance with data protection and retention laws.
Donbet screens customers against government and international sanction lists, including but not limited to UN, EU, FATF, and OFAC lists. If a customer is identified as a sanctioned individual or entity, Donbet will freeze or close the account and report as required by law. Politically Exposed Persons are subject to enhanced due diligence on onboarding and on an ongoing basis, with consideration given to source of funds and ongoing monitoring requirements.
Donbet maintains records of customer identification, transactions, and investigations for the duration required by applicable law, including records of cash flows, risk assessments, and decision-making. Data is stored securely, access is restricted to authorized personnel, and retention is aligned with regulatory requirements. Donbet complies with data protection laws in the relevant jurisdiction and implements encryption and access controls as appropriate.
Donbet provides ongoing AML training to employees, including identification of red flags, escalation procedures, and responsibilities for maintaining the integrity of the AML program. Training occurs at least annually and is updated to reflect regulatory developments.
Employees are obligated to promptly report suspicions through the MLRO. The MLRO evaluates reports and, where required by law, files suspicious activity reports with the appropriate authorities and cooperates with regulatory agencies.
This AML policy is reviewed at least annually and whenever regulatory changes arise, with amendments approved by senior management and communicated to staff.
Donbet reserves the right to refuse onboarding or terminate existing customer relationships where information requested under KYC procedures cannot be obtained or risk is deemed unacceptable following due diligence. Customers may request to discontinue use if policy terms are updated; service access may be suspended during investigations.