Anti-Money Laundering Policy

This AML Policy applies to all deposits and withdrawals on SnappyReels.

Objective of the AML Policy

We seek to offer the highest level of security to all users and customers of SnappyReels. To achieve this, a three-step account verification process is carried out to confirm the identity of our customers. The purpose is to verify that the details of the person registered are correct and that the deposit methods used are not stolen or being used by someone else, creating the general framework for the fight against money laundering. Depending on the player's nationality and origin, the payment method used, and the withdrawal method, different safety measures may apply.

SnappyReels puts reasonable measures in place to control and limit money-laundering (ML) risk, including dedicating appropriate resources to this objective.

SnappyReels is committed to high standards of anti-money laundering (AML) compliance in line with the standards of the Tobique Gaming Commission and applicable international guidelines, and requires management and employees to enforce these standards in preventing the use of its services for money-laundering purposes.

Regulatory framework

The AML programme of SnappyReels is designed to be compliant with, among others:

The licensing requirements of the Tobique Gaming Commission (licence number TGC-2026-CP-00142);

The Financial Action Task Force (FATF) recommendations on combating money laundering and the financing of terrorism;

EU Directive 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering and terrorist financing;

EU Regulation 2015/847 on information accompanying transfers of funds;

Various international regulations imposing sanctions or restrictive measures against persons and embargoes on certain goods and technology, including dual-use goods.

Definition of money laundering

For the purpose of this policy, money laundering is understood as:

The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person involved in the commission of such an activity to evade the legal consequences of their actions;

The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;

Participation in, association to commit, attempts to commit, and aiding, abetting, facilitating and counselling the commission of any of the actions referred to above.

Money laundering is regarded as such even when the activities that generated the property to be laundered were carried out in the territory of another state.

Organization of AML at SnappyReels

In accordance with applicable AML legislation, SnappyReels has assigned responsibility for the prevention of money laundering at the highest level: the full management of the company is in charge.

An Anti-Money Laundering Compliance Officer (AMLCO) is appointed and is responsible for the enforcement of the AML policy and procedures within SnappyReels. The AMLCO reports directly to general management.

AML policy changes and implementation

Each material change to this AML policy is subject to approval by the general management of SnappyReels and the Anti-Money Laundering Compliance Officer.

Three-step verification

Step one verification. Step one verification must be completed by every user before any withdrawal can be processed. Regardless of the payment method, deposit amount, withdrawal amount, withdrawal method or nationality of the user, step one verification must be completed first. Step one is a basic form completed by the user containing: first name, last name, date of birth, country of usual residence, gender and full address.

Step two verification. Step two verification must be completed by every user who deposits more than EUR 2,000 or makes any withdrawal. Until step two verification is completed, the withdrawal, tip or deposit will be placed on hold. Step two requires the user to upload a clear image of their official identity document, presented alongside a handwritten note containing a six-digit randomly generated number provided to them. Only an official ID may be used; the accepted document types may vary by country.

An electronic check is also run against the information submitted at step one. The electronic check verifies the data against two independent databases to ensure that the information matches the document and the name on the ID. If the electronic check fails or is not possible, the user is required to submit confirmation of their current address, such as a certificate of registration issued by the government or a similar official document.

Step three verification. Step three verification must be completed by every user who deposits more than USD 5,000, withdraws more than USD 5,000, or transfers another user more than USD 3,000. Until step three verification is completed, the withdrawal, tip or deposit will be placed on hold. For step three the user is asked to provide evidence of their source of wealth.

Customer identification and verification (KYC)

The formal identification of customers on entry into the business relationship is a vital element of both AML regulation and our KYC policy. This identification relies on the following fundamental principles:

A copy of the user's passport, ID card or driving licence, shown alongside a handwritten note mentioning the six-digit randomly generated number provided to the user. A second picture showing the user's face is also required. The user may blur out all information other than date of birth, nationality, gender, first name, last name and the photograph in order to protect their privacy.

All four corners of the ID must be visible in the same image and all required details must be clearly readable. SnappyReels may request additional details if necessary, and an employee may carry out additional checks depending on the situation.

Proof of address

Proof of address is verified through two independent electronic checks using separate databases. If the electronic checks fail, the user has the option to provide a manual proof.

Acceptable documents include a recent utility bill sent to the registered address issued within the last 3 months, or an official document issued by the government that proves the user's state of residence (for example, an electricity bill, water bill, bank statement or any official government correspondence addressed to the user).

To make the approval process as fast as possible, please ensure the document is submitted in a clear resolution where all four corners of the document are visible and all text is readable. An employee may carry out additional checks if necessary.

Source of funds

If a player deposits more than EUR 5,000 (cumulatively or in a single transaction), SnappyReels carries out a process to understand the source of wealth (SOW). Examples of acceptable sources of wealth include:

Ownership of a business; employment; inheritance; investment; family.

It is critical that the origin and legitimacy of that wealth is clearly understood. If this is not possible, an employee may request additional documents or evidence. The account will be frozen if the same user deposits this amount in a single transaction or across multiple transactions that cumulatively reach this threshold. An email will be sent to the user with instructions on how to complete the process. SnappyReels may also ask for a bank wire or credit card record to further confirm the identity and financial situation of the user.

Basic document for step one

The basic document is accessible via the settings page on SnappyReels. Every user must complete the following information: first name, last name, nationality, gender, date of birth.

The document is generated and stored automatically. An employee may carry out additional checks if necessary.

Risk management

In order to deal with the different risks and varying socio-economic conditions across jurisdictions, SnappyReels categorises every nation into one of three risk regions.

Region one, low risk. For users from a low-risk nation, three-step verification is applied as described above.

Region two, medium risk. For users from a medium-risk nation, three-step verification is triggered at lower thresholds. Step one is completed as usual. Step two is triggered after deposits of USD 1,000, withdrawals of USD 1,000 or tips to another user of USD 500. Step three is triggered after deposits of USD 2,500, withdrawals of USD 2,500 or tips to another user of USD 1,000. Users from a low-risk region who convert cryptocurrency into any other currency are also treated as medium-risk for verification purposes.

Region three, high risk. Users from high-risk regions are restricted from accessing the service. The list of high-risk regions is reviewed regularly to reflect a changing regulatory and geopolitical environment.

Additional measures

In addition to the above, automated monitoring overseen by the AML Compliance Officer flags any unusual behaviour and reports it to a SnappyReels employee.

On a risk-based approach, human employees re-check work carried out by automated systems or other employees and may repeat or extend checks depending on the situation.

A data scientist supported by modern analytical systems also looks for unusual patterns such as: deposits and withdrawals without meaningful betting sessions; attempts to use different bank accounts for deposits and withdrawals; nationality changes; currency changes; behaviour and activity changes; and checks to confirm that an account is being used by its original owner.

A user must also use the same method for withdrawal as they used for deposit, at least for the amount of the initial deposit, in order to prevent money laundering.

Enterprise-wide risk assessment

As part of its risk-based approach, SnappyReels has conducted an AML Enterprise-Wide Risk Assessment (EWRA) to identify and understand the risks specific to SnappyReels and its business lines. The AML risk policy is set after identifying and documenting the risks inherent to those business lines, including the services offered, the users to whom those services are offered, the transactions performed, the delivery channels used, the geographic locations of SnappyReels's operations, customers and transactions, and other qualitative and emerging risks.

The identification of AML risk categories is based on SnappyReels's understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to address the additional risks that operating online brings with it. The EWRA is reassessed at least annually.

Ongoing transaction monitoring

AML Compliance ensures that ongoing transaction monitoring is conducted to detect transactions which are unusual or suspicious compared with the customer profile. This monitoring is conducted on three levels.

First line of control. SnappyReels works only with trusted Payment Service Providers, each of which has effective AML controls in place, in order to prevent the large majority of suspicious deposits onto SnappyReels from being made without proper KYC procedures being applied to the customer.

Second line of control. SnappyReels ensures that any contact with the customer, player or their authorised representative gives rise to the exercise of due diligence on transactions on the account concerned. This includes in particular: requests for the execution of financial transactions on the account; and requests in relation to means of payment or services on the account. The three-step verification described above, together with adjusted risk management, is designed to provide the necessary information about every customer of SnappyReels at all times. All transactions are reviewed by employees who are overseen by the AML Compliance Officer, who reports to general management. Specific transactions referred to the customer support manager, and where necessary the Compliance Manager, are also subject to due diligence.

Determination of the unusual nature of a transaction depends on a subjective assessment in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty. These checks are carried out by an automated system, with an employee cross-checking for additional security. Transactions for which it is difficult to gain a proper understanding of the lawful activities and origin of funds will be considered atypical (as they are not directly justifiable). Any SnappyReels staff member must inform the AML division of any atypical transactions they observe and cannot attribute to a lawful activity or source of income known of the customer.

Third line of control. As a last line of defence against money laundering, SnappyReels carries out manual checks on all suspicious and higher-risk users in order to fully prevent money laundering. If fraud or money laundering is identified, the relevant authorities will be informed.

Reporting of suspicious transactions

In its internal procedures, SnappyReels describes in precise terms, for the attention of its staff, when it is necessary to report and how to proceed with such reporting. Reports of atypical transactions are analysed by the AML team in accordance with the methodology described in those internal procedures.

Depending on the result of this examination and the information gathered, the AML team:

Decides whether it is necessary to send a report to the competent Financial Intelligence Unit (FIU) or to the Tobique Gaming Commission, in accordance with applicable legal obligations; and decides whether it is necessary to terminate the business relationship with the customer.

Procedures

The AML rules, including minimum KYC standards, are translated into operational guidance or procedures that are available to relevant staff on SnappyReels's internal systems.

Record keeping

Records of data obtained for the purpose of identification are kept for at least ten years after the business relationship has ended. Records of all transaction data are kept for at least ten years following the carrying-out of the transactions or the end of the business relationship. These records are stored securely and in encrypted form, both online and offline.

Training

SnappyReels's human employees carry out manual controls on a risk-based approach, for which they receive specialised training. The training and awareness programme includes:

A mandatory AML training programme reflecting the latest regulatory developments, for all staff in contact with financial operations; and academic AML learning sessions for all new employees. The content of this training programme is established in line with the kind of business the trainees are working on and the positions they hold. Sessions are delivered by an AML specialist working within SnappyReels's AML team.

Auditing

Internal audit regularly carries out missions and produces reports on AML activities.

Data security

All data provided by any user will be kept secure and will not be sold or shared with any third party, except where required by law or where it is necessary to prevent money laundering, in which case data may be shared with the AML authority of the affected jurisdiction, including the Tobique Gaming Commission. SnappyReels follows applicable data-protection rules, including the principles set out in EU Directive 95/46/EC and its successor regulations.

Contact us

If you have any questions about our AML and KYC policy, please contact our Compliance Team at compliance@snappyreels.com.

If you have any complaints about our AML and KYC policy, or about the checks carried out on your account or person, please contact us by email at compliance@snappyreels.com.