Introduction

Bd111 maintains a Know Your Customer (KYC) program to identify customers, assess risk, and prevent money laundering, terrorist financing, underage gambling, and other unlawful activities. This Policy governs all Bd111 accounts and applies to onboarding, verification, ongoing monitoring, and data handling related to customer information.

Scope

The provisions herein apply to every Bd111 user who holds a real‑money account and to all Bd111 operations that collect, verify, or monitor customer information. The Policy adopts a risk‑based approach, tailoring identity verification and monitoring to the level of risk posed by the customer, transaction type, and geography.

Regulatory Framework and Risk-Based Approach

Bd111 operates in compliance with applicable anti‑money laundering and counter‑terrorist financing requirements. The Company assesses risk across four categories: Customer, Geography, Product/Service, and Channel. The assessment determines the level of due diligence, monitoring intensity, and review frequency, with senior management oversight for higher‑risk determinations.

Identification and Verification (KYC)

On registration for real‑money play, Bd111 requires identification, address verification, and payment verification. Applicants must meet age requirements prior to account activation. Verification progresses in stages and may be performed prior to the first withdrawal or upon reaching predefined risk triggers.

Documentary Requirements and Submission

Bd111 shall request the following documents as part of standard verification. Submission is performed via the Documents tab within the My Account section. The required items may vary by deposit method and jurisdiction, and Bd111 may request supplementary data as needed:

  • Identification: A valid photo ID (passport, national ID card, or government ID). Include front and back scans. In the absence of photo ID, a birth certificate accompanied by a recent photo of the user holding the certificate may be accepted.
  • Proof of Address: A utility bill or bank statement issued within the last three months showing the user’s name and residential address. Mobile phone bills are not acceptable.
  • Proof of Payment: Documentation corresponding to the deposit method used, as described below.
  • Card Payments: Copies of all card(s) used, displaying the cardholder’s signature and the first six and last four digits. Black out the CVV and the middle digits on the front; the cardholder’s name must be visible.
  • eWallets: Screenshot of the eWallet account showing the registered email, account number, and identifying details.
  • Bank Statements: Bank statement issued within the last three months, including the bank name, account number, IBAN, and BIC; all four corners visible. Submit a screenshot or PDF showing the relevant deposit(s).
  • Cryptocurrency: Screenshots showing the transaction and the wallet profile with linked email, user ID, and identifying information.
  • Pre‑paid Vouchers: Not accepted for verification where applicable.

Documents may be submitted by the user directly through the Documents tab in My Account. Bd111 reserves the right to request additional information as needed to complete verification.

Verification Triggers and Timelines

Standard verification is triggered by onboarding activities and by risk‑based review. The Company may require verification when any of the following occur:

  • Total transactions reach or exceed USD 1,000.
  • The customer presents elevated risk of money laundering or terrorist financing based on risk assessment.
  • Behavior or activity suggests potential non‑compliance with Terms and applicable law.
  • Other circumstances deemed necessary by Bd111 personnel.

Bd111 aims to complete standard verification within 3 business days of receiving complete documentation. If documents are incomplete, the user will be notified and given a defined period to supply outstanding items. In urgent cases, higher‑level review may be conducted with accelerated timelines.

Enhanced Verification for PEPs and High‑Risk Jurisdictions

Additional verification measures apply to Politically Exposed Persons (PEPs) and customers from high‑risk jurisdictions. Bd111 may require evidence of the source of wealth, enhanced documentation, and direct confirmation with senior compliance personnel. Final approval for enhanced verification rests with senior management. If verification cannot be completed, Bd111 may restrict activity or terminate the relationship and may report the matter to relevant authorities as required by law.

Ongoing Monitoring and Transaction Monitoring

Bd111 conducts ongoing monitoring of all customer activity to detect suspicious or inconsistent behaviour. Indicators of suspicious activity include, but are not limited to:

  • Multiple cards or payment instruments used in rapid succession.
  • Unusual or unexplained transaction patterns or error codes.
  • Geolocation inconsistencies (residency, IP, device identifiers) or mismatched account information.
  • Reluctance to undergo verification or to provide requested documentation.

Suspicious activity identified by the monitoring systems is escalated to the internal anti‑fraud team for assessment and may be reported to authorities where legally required.

Transactions and Payment Handling

Bd111 requires that deposits and withdrawals be associated with the same account holder. No cash deposits are accepted. Withdrawals are issued to the funding source used for the deposit, or to a banking instrument that can be reliably matched to the user. Payments from anonymous or prepaid instruments are not accepted, and third‑party payments are prohibited unless specifically approved by Bd111 compliance.

Record‑Keeping and Data Protection

Bd111 maintains records of verification documents, customer data, and transactional evidence in accordance with applicable data protection and financial‑crime regulations. Retention periods align with EU data protection standards, relevant local laws, and Bd111’s Privacy Policy. Access to records is limited to authorized personnel and regulated by Bd111’s internal controls.

Data Sharing and Regulatory Disclosures

Bd111 may share information with competent regulatory, supervisory, or law‑enforcement authorities in accordance with applicable law or regulatory requirements. Such disclosures are limited to what is necessary to achieve compliance with legal obligations and to protect Bd111, its customers, and the public interest.

Amendments and Modifications

This Policy may be amended from time to time. Bd111 will notify registered users of material changes via email. Continued use of services after notification constitutes acceptance of the revised Policy.

Roles and Responsibilities

The Compliance Team is responsible for implementing and maintaining KYC/AML controls, with the Board providing oversight for material risk decisions. Bd111 staff shall be trained to identify red flags and to exercise appropriate escalation procedures in accordance with this Policy.

Definitions

Key terms used in this Policy include: KYC (Know Your Customer), CDD (Customer Due Diligence), EDD (Enhanced Due Diligence), AML (Anti‑Money Laundering), CFT (Countering the Financing of Terrorism), and PEP (Politically Exposed Person).