Effective Date: June 1, 2025
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros
IOGr B.V. (“Company”, “we”, “our” or “us”) operates the website jili-games.net, including all associated subdomains, tools, and services (collectively, the “Website”). This KYC & AML Policy explains how we identify, verify, and monitor our B2B clients to ensure compliance with regulatory standards and to prevent misuse of our services for illicit activities.
1. Purpose and Scope
This Policy sets forth our Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures, designed to mitigate risks such as money laundering, terrorist financing, and other criminal misuse. It applies universally to all B2B partners—operators, resellers, service integrators, and other corporate clients engaging with the Company.
2. Risk-Based Approach (RBA)
We follow a structured risk-based framework during client onboarding and ongoing monitoring. Client risk profiles are assessed considering jurisdiction, ownership structure, business model, and other factors. Based on this assessment, clients are assigned either Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD). Risk profiles are reviewed at least annually or whenever a material change arises.
3. Due Diligence Requirements
3.1 Customer Due Diligence (CDD)
Clients must provide the following documents (dated within the last 3 months where applicable):
- Certificate of Incorporation / Trade Register Extract
- Articles or Memorandum of Association
- Proof of business address (e.g., utility bill or bank statement)
- Corporate structure chart showing shareholders and Ultimate Beneficial Owners (UBOs)
- ID documents for directors and UBOs (>25% ownership)
- Proof of identity (government-issued photo ID: passport or national ID)
- Proof of residence (e.g., utility bill or bank statement)
3.2 Enhanced Due Diligence (EDD)
EDD applies to clients falling under high-risk criteria like:
- Operations from FATF high-risk or non-cooperative jurisdictions
- Complex or opaque ownership structures (e.g. nominee shareholders, offshore holdings)
- Ownership/control by Politically Exposed Persons (PEPs)
- History of regulatory infractions or other elevated risk indicators
In such cases, additional documentation may be required:
- Source of Funds / Source of Wealth evidence
- Third-party AML audit reports
- Proof of relevant gaming licenses
- Additional background and reputational checks
4. Ongoing Monitoring
We periodically review all B2B clients—at least annually or after any significant change in risk status, ownership, or jurisdiction. If suspicious activity is detected, services may be temporarily suspended pending further investigation. Clients must promptly notify us of any legal or structural changes.
5. PEP and Sanctions Screening
All directors and UBOs undergo screening against global sanctions and PEP watchlists (e.g., UN, EU, OFAC, Dow Jones, Refinitiv, ComplyAdvantage). Positive matches may trigger heightened scrutiny, potential onboarding rejection, or EDD.
6. Recordkeeping
All KYC and AML documentation—physical or digital—is retained for a minimum of six (6) years post-termination of the business relationship, in line with Anjouan AML regulations.
7. Restricted Jurisdictions
We do not onboard clients registered in, or owned by individuals from:
- FATF high-risk or non-cooperative jurisdictions
- Countries under UN, EU, or OFAC sanctions
- The Union of the Comoros (for white‑label services aimed at that jurisdiction)
- Other territories restricted by the Anjouan Offshore Financial Authority
8. Failure to Comply
Failure to supply accurate or timely KYC documentation may result in:
- Rejection of onboarding requests
- Suspension of services
- Termination of business relationships
- Reporting to regulatory authorities
9. Amendments
We reserve the right to modify this Policy as regulations evolve. Material changes will be communicated to our clients in advance.