AML Policy

Anti-Money Laundering & Counter-Terrorism Financing — ApexTechnologies Pvt. Ltd. — January 2025

ApexTechnologies operates a zero-tolerance policy towards money laundering and financial crime. All suspicious activity is reported to the relevant authorities.

Customer Due Diligence (CDD)

We verify the identity of all customers before allowing withdrawals and in other circumstances required by law. This includes name, date of birth, residential address, and government-issued ID.

Enhanced Due Diligence (EDD)

For high-risk customers, politically exposed persons (PEPs), or large transactions, we apply enhanced checks including source of funds and wealth documentation.

Transaction Monitoring

We monitor all financial activity on the platform for patterns associated with money laundering, terrorist financing, or other financial crime. Suspicious activity is reviewed and reported as required.

Suspicious Activity Reporting

We have a legal obligation to report suspicious activity to relevant financial intelligence authorities. We cooperate fully with law enforcement and regulatory bodies.

1. Introduction & Commitment

ApexTechnologies Pvt. Ltd. ("the Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This policy has been established to prevent Apex Jackpot from being used as a vehicle for financial crime of any kind. The Company takes its legal and ethical obligations in this area extremely seriously.

2. Regulatory Framework

This AML Policy has been designed in accordance with applicable financial crime legislation, including Prevention of Money Laundering Act (PMLA) requirements in India and international standards set by the Financial Action Task Force (FATF). We operate under a gaming licence and are subject to ongoing regulatory oversight. Our AML/CTF programme is reviewed and updated regularly.

3. Know Your Customer (KYC)

All users of Apex Jackpot are subject to our Know Your Customer (KYC) programme. KYC verification is mandatory before processing any withdrawal. Verification may be required at account registration or at any point during the customer relationship. Documents required may include: government-issued photo ID (Aadhaar, PAN card, passport or driving licence), proof of address (utility bill, bank statement), and selfie verification. Failure to complete KYC will result in withdrawal restrictions.

4. Prohibited Activity

The following activities are strictly prohibited on Apex Jackpot: depositing funds obtained through criminal activity; using the platform to layer, place, or integrate proceeds of crime; structuring transactions to avoid reporting thresholds; using the accounts of other persons or fictitious identities; providing false information during KYC verification. Violations will result in immediate account suspension, freezing of funds, and reporting to relevant authorities.

5. Source of Funds

The Company reserves the right to request evidence of the source of funds deposited onto the platform at any time. This is particularly applicable for large deposits, high-volume play, or where we have reason to suspect financial irregularity. Acceptable evidence includes recent payslips, bank statements, tax returns, proof of business income, or documentation evidencing an inheritance or sale of assets. Failure to provide satisfactory evidence may result in the account being suspended or funds being frozen pending investigation.

6. Politically Exposed Persons (PEPs)

Politically Exposed Persons (PEPs) and their close associates are subject to enhanced due diligence measures. If you are or become a PEP, you must notify us immediately. The Company may apply additional scrutiny to accounts identified as belonging to PEPs and may require additional documentation before allowing deposits or withdrawals.

7. Record Keeping

The Company retains all KYC documents, transaction records, and AML investigation files for a minimum of 5 years following the end of the customer relationship, or longer where required by applicable law. All records are stored securely and accessed only by authorised personnel.

8. Staff Training

All employees of ApexTechnologies with access to financial or customer data receive regular training on AML and CTF obligations, red flags, and internal reporting procedures. Our compliance team is responsible for maintaining and updating the AML programme in line with regulatory developments.

9. Reporting

The Company files Suspicious Transaction Reports (STRs) with the relevant Financial Intelligence Unit (FIU) where required by law. We maintain a dedicated compliance officer responsible for AML oversight. Players should be aware that we are legally prohibited from disclosing (tipping off) that a suspicious activity report has been filed in relation to their account.

10. Contact

For questions related to our AML Policy or KYC requirements, please contact our Compliance team at compliance@apexjackpot.com. We will respond to all enquiries within 5 business days.