Last Updated: January 15, 2026
Regulatory Basis: Prevention of Money Laundering Act (PMLA) 2002, PMLA Rules 2005, FIU-IND guidelines, UIDAI regulations
1. Purpose of This Policy
This KYC/AML Policy establishes our procedures for:
- Verifying the identity of every user before account activation
- Preventing money laundering, terrorist financing, and financial crime
- Ensuring only adults (18+) access our service
- Maintaining compliance with Indian regulatory requirements
- Monitoring transactions for suspicious activity
- Cooperating with regulatory authorities when required
यह KYC/AML नीति पहचान सत्यापन, मनी लॉन्ड्रिंग रोकथाम, आयु सत्यापन, नियामक अनुपालन, और लेनदेन निगरानी के लिए हमारी प्रक्रियाएं स्थापित करती है। यह कानूनी आवश्यकता है और आपकी सुरक्षा में मदद करती है।
2. Legal Framework
Our KYC/AML procedures are based on these Indian regulations:
- Prevention of Money Laundering Act (PMLA) 2002 — Primary AML legislation
- PMLA Rules 2005 — Detailed compliance requirements
- Information Technology Act 2000 — Digital identity verification
- Aadhaar Act 2016 and UIDAI regulations — Aadhaar-based eKYC standards
- Income Tax Act 1961 — PAN requirements and TDS obligations
- FIU-IND guidelines — Reporting of suspicious transactions
- RBI KYC Master Directions — Financial transaction KYC standards
3. Customer Identification Procedure (CIP)
3.1 Standard KYC Documents
All users must provide these documents for account activation:
| Document Type | Purpose | Requirement |
|---|---|---|
| Aadhaar Card | Identity + address + age + photo | Mandatory (preferred) |
| PAN Card | Tax compliance / TDS | Mandatory |
| Selfie/Photograph | Liveness check, fraud prevention | Mandatory |
| Bank Account / UPI | Deposits/withdrawals | Mandatory (in your name) |
| Alternate ID (Passport/Voter) | If Aadhaar unavailable | Alternative |
3.2 Verification Methods
- Aadhaar eKYC (Preferred): Instant digital verification via UIDAI-approved OTP. No document scanning needed. Most secure and fastest method.
- Offline Aadhaar: Upload clearly scanned Aadhaar via WhatsApp with masked Aadhaar number (last 4 digits visible only).
- Video KYC: Required for high-value users (above ₹5 lakh/year deposits). 20-minute video call with verification agent.
- Enhanced Due Diligence (EDD): For high-risk users (PEPs, unusual transaction patterns), additional documentation and income verification.
4. Prohibited Customer Categories
We cannot accept users in these categories:
- Individuals under 18 years of age (strictly enforced)
- Individuals on UN or Indian sanctions lists
- Individuals with confirmed history of gambling fraud or money laundering
- Individuals from jurisdictions where our service is prohibited
- Professional athletes, coaches, or officials of events we offer betting on (conflict of interest)
- Certain government officials with specific legal restrictions
- Undischarged insolvents or bankrupt individuals
- Those who have self-excluded and not completed their exclusion period
5. Risk Assessment
We categorize users by risk level for appropriate monitoring:
Low Risk
- Salaried individuals with stable income
- Consistent, moderate betting patterns
- Deposits from salary account
- No AML red flags
- Monitoring: Standard transaction monitoring
Medium Risk
- Self-employed individuals or business owners
- Higher deposit amounts (₹1-5 lakh annually)
- Variable income patterns
- Cross-border transactions
- Monitoring: Enhanced transaction review, periodic profile updates
High Risk
- Politically Exposed Persons (PEPs) and family members
- Cash-intensive businesses
- Deposits exceeding ₹10 lakh annually
- Complex source of funds
- Unusual transaction patterns
- Monitoring: Enhanced due diligence, video KYC, regular source-of-funds verification
6. Transaction Monitoring
We continuously monitor transactions for suspicious patterns using automated systems and manual review:
6.1 Automated Monitoring Triggers
- Deposits above ₹1 lakh in single transaction
- Cumulative deposits above ₹10 lakh in 12 months
- Rapid deposit-withdrawal patterns (under 24 hours)
- Multiple failed deposits followed by successful ones
- Third-party payment attempts
- Deposits/withdrawals during unusual hours
- Sudden changes in user behavior patterns
- Structuring patterns (multiple transactions just below thresholds)
6.2 Manual Review
When triggers activate, our AML team manually reviews the account, transaction history, and user profile. Most reviews clear normally within 24-48 hours. Genuine users rarely notice — only those with actual suspicious activity face account restrictions.
7. Source of Funds (SoF)
For larger transactions, we may request source-of-funds documentation. Acceptable documents include:
- Last 3-6 months salary slips
- Income tax returns (last 2 years)
- Bank statements showing salary/income credits
- Business financial statements (for business owners)
- Investment proceeds documentation (mutual fund redemption, FD maturity)
- Property sale agreement (if proceeds used)
- Inheritance/gift documentation (with tax compliance proof)
- Legal settlement documentation
8. Suspicious Transaction Reporting (STR)
When we identify genuinely suspicious activity under PMLA Rules, we are legally required to:
- File a Suspicious Transaction Report (STR) with FIU-IND within prescribed timelines
- NOT inform the user about the report (tipping-off prohibition)
- Cooperate with FIU-IND and any subsequent investigation
- Maintain detailed records of the STR and underlying evidence
- Continue monitoring the account pending investigation outcome
Suspicious activity reporting is a legal obligation, not a choice. Failure to report can result in severe penalties for our company and individual compliance officers.
9. Data Retention for AML Purposes
Under PMLA Rules, we must retain the following for minimum periods:
- Customer identification records: 10 years after business relationship ends
- Transaction records: 10 years after transaction
- STR records: 10 years
- Investigation and correspondence records: 10 years
This retention applies even if you close your account. It's a legal requirement we cannot waive.
10. Your Rights
While AML compliance is mandatory, you retain rights:
- Right to know verification requirements — We'll clearly explain what documents are needed
- Right to reasonable timelines — We process KYC quickly
- Right to appeal decisions — Escalate account restrictions to senior review
- Right to data privacy — KYC data is protected per Privacy Policy
- Right to accurate records — Request corrections to your KYC information
Note: Some rights are limited by AML tipping-off restrictions — we may not be able to disclose all details of investigations.
11. Common KYC Scenarios
New Account Setup
- Register via WhatsApp with basic details
- Submit Aadhaar via eKYC OTP (instant) or document upload
- Submit PAN for tax compliance
- Take selfie for liveness verification
- Provide bank account / UPI ID
- Account activated within 15-30 minutes
Changed Personal Information
- Message 'UPDATE KYC' on WhatsApp
- Provide updated document (new address proof, marriage certificate for name change, etc.)
- Re-verification within 24 hours
Large Transaction Verification
- Automated system flags the transaction
- Support agent messages you on WhatsApp requesting source of funds
- You provide documentation (salary slip, ITR, bank statement)
- Review completed within 72 hours
- Transaction proceeds or is explained if blocked
12. Contact & Support
For KYC/AML related queries:
- WhatsApp: Click here to chat — mark message 'KYC' or 'AML' for priority routing
- Response time: KYC queries — 15 minutes. AML queries — 2 hours.
- Compliance Officer: For serious AML matters, request escalation to our designated Principal Officer