Purpose and Scope

Un777 adopts this KYC and AML Policy to comply with applicable anti-money laundering and countering the financing of terrorism laws and to govern all customer relationships, transactions, and activities conducted on the Un777 platform. This Policy applies to all customers, accounts, payments, and interactions processed through Un777, and remains in effect until replaced by a subsequently approved policy.

Definitions

  • Client: any person or legal entity using or seeking access to Un777 services.
  • Beneficial Owner: the natural person(s) who ultimately own or control the Client or on whose behalf a transaction is being conducted.
  • PEP: a politically exposed person, their immediate family members and close associates.
  • KYC: Know Your Customer procedures to verify identity and assess risk.
  • AML/CFT: anti-money laundering and countering the financing of terrorism controls.

Identification and Verification of Clients

Un777 shall identify and verify clients in line with KYC requirements. Verification is performed on onboarding and on an ongoing basis to reflect changes in risk profile or personal data.

  1. Legal name, date of birth, country of residence, primary contact details, and (for entities) information on the legal structure and beneficiaries must be collected from each client.
  2. Acceptable identity documents include a government-issued passport, national identity card, or driving license. For entities, corporate documents and identity details of beneficial owners must be obtained. Documents must be current and legible.
  3. Proof of address must be provided via a document issued within the last three months, such as a utility bill or bank reference that displays the client’s name and residential address.
  4. When requested, clients shall provide the front of a payment card showing the cardholder name, expiry date, and the first six and last four digits of the card number, and the back of the card with the cardholder’s signature; CVV/CVC must be obscured.
  5. Un777 shall monitor the client’s information on an ongoing basis and shall conduct enhanced due diligence for any changes or indicators of increased risk.
  6. If the client’s information raises high-risk concerns, Un777 may request additional documentation and suspend or restrict activity pending resolution.
  7. Clients must immediately notify Un777 of any changes to personal or contact information.

KYC Procedures

To open an account, a client must provide a valid email address, create a password, and supply personal information including name, date of birth, and phone number. The name on the account must correspond to the client’s true and legal name. Un777 reserves the right to request satisfactory proof of identity at any time, including copies of government-issued IDs and payment cards used for funding. If requested information is not provided, Un777 may suspend activity or close the account. Documentation may be reviewed within 30 calendar days.

Clients certify that information provided is accurate, complete, and current and must update data promptly if changes occur. A single account per client is allowed. Duplicate accounts are prohibited; creation of a duplicate account may result in cancellation of transactions, forfeiture of bonuses and winnings, and retention or return of funds in accordance with policy. Anonymous or non-identified accounts are prohibited under AML/CFT rules.

Account Verification Levels (KYC Tiers)

Un777 employs a tiered KYC framework with Levels 0–3. Each level imposes corresponding verification requirements and deposit/withdrawal limits as described below.

  1. Level 0 – None: No verification required. Deposits may be accepted up to a defined cap; withdrawals are disabled until Level 1 verification is completed.
  2. Level 1 – Basic Identity: Required before the first withdrawal. Mandatory fields: first name, last name, date of birth, full residential address, country, and a valid email. Data must match payment processors’ records. Deposits may be limited to a defined threshold (e.g., USD 2,000).
  3. Level 2 – Identity Verification: Triggered when lifetime deposits or withdrawals exceed a threshold (e.g., USD 2,000) or when the client engages in high-risk activity. Required documents: government-issued ID (front/back), a selfie with the ID, and proof of address. Identity data may be cross-verified with electronic databases. If automated checks fail, manual review is conducted and withdrawals may be held until resolution.
  4. Level 3 – Source of Funds: Triggered when cumulative deposits or withdrawals exceed a higher threshold (e.g., USD 50,000) or the client demonstrates unusual activity. Required evidence may include payslips, audited accounts, inheritance documents, investment statements, or equivalent documentation demonstrating the source of funds. Clients will be notified and given a defined period (e.g., 28 days) to supply documentation. Failure to comply may result in account suspension or termination.

Proof of Address and Proof of Funds

Address verification is normally performed via independent electronic databases. If checks fail, clients must provide dated documentation (within the last three months) such as a utility bill, bank statement, or government correspondence showing the client’s name and address. Source-of-funds evidence should clearly demonstrate lawful origin of funds and may include employment payslips, bank statements, inheritance records, or investment statements.

High-Risk Jurisdictions and Geographical Risk

Un777 recognises that certain jurisdictions present inherently higher money-laundering and terrorism-financing risks. The company applies enhanced due diligence and monitoring for clients with links to such jurisdictions. Geographical risk assessments are reviewed at onboarding and on an ongoing basis to determine the necessity and scope of enhanced controls.

Record Keeping

Identification records are retained for at least six years after the termination of the business relationship. Transaction records are retained for a minimum of ten years after execution or account closure. Records are stored securely in encrypted archives, accessible only to authorized personnel.

Data Security and Privacy

Un777 implements appropriate technical and organizational measures to protect client data against loss, theft, or unauthorized access. Data may be disclosed only as required by law, with explicit client consent, or to fulfil AML obligations. Un777 complies with applicable data protection laws and regulations governing the processing of personal data.

Governance, Training, and Reporting

The AML Compliance Officer has ultimate responsibility for the AML program and the integrity of the KYC process. All employees, managers, and directors undergo AML training, with ongoing updates. Any suspected violation of this Policy must be reported to the AML Compliance Officer; if the officer is involved, the report should be escalated to the Chief Executive Officer.

Transaction Monitoring and Suspicious Activity

Un777 monitors transactions for unusual or potentially suspicious activity. When indicators arise, funds may be frozen pending investigation, and regulators may be notified in accordance with applicable law and licensing obligations.

Policy Updates and Communication

Material amendments to this Policy require approval by the Un777 board and the AML Compliance Officer. The most recent update is reflected at the top of this document and includes the effective date.

Questions and Contact

Questions regarding this Policy should be directed to Un777’s Compliance and Support channels via the in-account contact options. All inquiries will be handled in accordance with applicable law and licensing requirements.