This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Star Bright Media S.R.L, the operator of Betpanda at betpandaonline.fr, in relation to the prevention of money laundering, terrorist financing, and related financial crime. All registered users of betpandaonline.fr are required to read and comply with this Policy alongside our Terms & Conditions. By creating an account and transacting on betpandaonline.fr, you acknowledge and accept the procedures described below.

1. Operator Details and Regulatory Context

Betpanda is owned and operated by Star Bright Media S.R.L ("the Company", "we", "us", "our"), operating under a Costa Rica gaming licence. Although Costa Rica does not mandate a prescriptive AML regime equivalent to those found in EU-regulated jurisdictions, the Company voluntarily applies robust anti-money laundering and know your customer controls consistent with internationally recognised Financial Action Task Force (FATF) standards. We do this because it is the right way to run a responsible gaming business, because it protects our players, and because it protects the integrity of betpandaonline.fr as a platform.

Betpanda operates exclusively with cryptocurrency. We accept Bitcoin (BTC), Ethereum (ETH), Binance Coin (BNB), Lightning Network payments, and more than 30 other supported digital assets. The all-crypto payment environment eliminates traditional fiat conversion points but does not reduce the Company's obligation to screen transactions, identify customers, and report suspicious activity. Our AML and KYC framework is designed specifically for a crypto-native operation.

2. Purpose and Scope

The purpose of this Policy is to:

• Establish clear procedures for identifying and verifying customers ("Know Your Customer" or KYC);
• Define the standards by which Betpanda monitors account activity and transactions for suspicious behaviour;
• Describe the Company's approach to reporting suspicious transactions and cooperating with competent authorities;
• Set out the responsibilities of Betpanda's compliance personnel and, where relevant, the obligations of players;
• Ensure that betpandaonline.fr is not used, directly or indirectly, for money laundering, terrorist financing, fraud, or any other financial crime.

This Policy applies to every account registered at betpandaonline.fr, regardless of the player's country of residence, the cryptocurrency used, or the volume of activity on the account. It applies to casino play, sportsbook wagering, and any promotional or bonus activity.

3. Definition of Money Laundering and Terrorist Financing

For the purposes of this Policy, money laundering refers to the process by which individuals or organisations seek to conceal the origins of funds obtained through criminal activity and introduce those funds into the legitimate financial system so that they appear to have a lawful source. This process typically involves three stages:

• Placement — the introduction of illicit funds into a financial or gaming system;
• Layering — the use of transactions to obscure the trail of the funds and distance them from their source;
• Integration — the re-entry of laundered funds into the legitimate economy in a form that appears clean.

Terrorist financing refers to the provision or collection of funds, whether from legitimate or illegitimate sources, with the intention or knowledge that those funds will be used, in whole or in part, to carry out terrorist acts or to support terrorist organisations.

Betpanda expressly prohibits the use of betpandaonline.fr for any form of money laundering, terrorist financing, fraud, or other financial crime. Any account found to be engaged in such activity will be suspended immediately, funds held pending investigation, and relevant information disclosed to competent authorities.

4. AML Compliance Officer

The Company has appointed a designated AML Compliance Officer ("AMLCO") who carries responsibility for the day-to-day implementation and oversight of this Policy. The AMLCO's responsibilities include:

• Receiving and evaluating internal suspicious activity reports from operational and support staff;
• Making decisions on whether to file external reports with relevant authorities;
• Ensuring that KYC documentation is collected, stored, and reviewed to the required standard;
• Keeping this Policy current with applicable regulatory guidance and FATF recommendations;
• Overseeing staff AML training programmes;
• Conducting periodic internal audits of AML controls and transaction monitoring outputs.

The identity of the AMLCO is held internally and is available to competent regulatory or law enforcement authorities upon formal request. Players wishing to raise a compliance concern may do so through our 24/7 Live Chat or by email to our support team.

5. Know Your Customer (KYC) — Overview

Betpanda operates a streamlined registration process. Creating an account at betpandaonline.fr requires only a valid email address and a password; no document upload is required at the point of sign-up. This approach is designed to reduce friction for genuine players and reflects the nature of a crypto-native platform where wallet address verification provides an initial layer of transactional authentication.

However, this does not mean that Betpanda operates without identity verification. KYC verification will be triggered in accordance with the conditions set out in this Policy and in our Terms & Conditions. When a KYC request is issued, players are required to cooperate promptly and fully. Failure to provide satisfactory documentation will result in restrictions being placed on the account, including suspension of withdrawal rights, until verification is completed to the Company's satisfaction.

6. KYC Triggers

Betpanda will initiate a KYC request on an account under any of the following circumstances, which are non-exhaustive:

• The cumulative value of deposits on the account reaches an internal threshold that the Company considers material in the context of its risk-based approach;
• The cumulative value of withdrawals on the account reaches an internal threshold;
• A single transaction is identified that exceeds internal risk thresholds;
• The account exhibits transaction patterns or betting behaviour that are inconsistent with its stated or apparent profile;
• Automated transaction monitoring flags the account for further review;
• A withdrawal request is submitted and the account has not previously completed verification;
• There are indicators of account sharing, third-party funding, or multiple-account activity;
• The account appears on or matches entries in sanctions screening lists or politically exposed person (PEP) databases;
• Law enforcement, a regulatory authority, or a financial intelligence unit makes a request in relation to the account;
• The AMLCO or a compliance team member exercises discretionary judgement that verification is warranted for any reason consistent with this Policy.

7. Customer Due Diligence (CDD)

When a KYC request is issued, standard Customer Due Diligence will require the player to supply the following documentation. All documents must be current, legible, and unaltered.

7.1 Proof of Identity

One of the following government-issued documents displaying the player's full legal name, date of birth, photograph, and document number:

• Valid national passport;
• Valid national identity card (both sides);
• Valid government-issued driving licence (both sides, where it includes a photograph).

7.2 Proof of Address

One of the following documents, dated within the preceding three months, displaying the player's full name and residential address:

• Utility bill (gas, electricity, water, or fixed-line telecommunications);
• Bank statement or credit card statement from a recognised financial institution;
• Official government correspondence;
• Municipal or council tax document.

7.3 Proof of Payment Method

Because betpandaonline.fr operates exclusively in cryptocurrency, confirmation of wallet ownership may be requested. This typically takes the form of a signed message from the wallet address used for deposits, or a screenshot of the wallet interface clearly showing the relevant address and the player's control of that wallet. Third-party wallet use — depositing funds from a wallet that does not belong to the account holder — is not permitted and will be treated as a serious compliance concern.

7.4 Selfie / Liveness Check

The Company reserves the right to request a real-time selfie or liveness verification photograph in which the player holds a copy of their identity document alongside a handwritten note bearing the date and the Betpanda account email address. This step may be applied where the compliance team has difficulty confirming document authenticity by static image alone.

8. Enhanced Due Diligence (EDD)

Enhanced Due Diligence applies where a standard CDD review indicates elevated risk. Circumstances that will trigger EDD include but are not limited to:

• The player is identified as a Politically Exposed Person (PEP) — that is, an individual who holds or has held a prominent public function, or a close family member or known associate of such a person;
• The player's country of residence or citizenship is classified by FATF as high-risk or subject to increased monitoring;
• Transaction volumes are high relative to the account's stated source of funds;
• There are inconsistencies between the player's stated profile and their observed activity;
• The account has been subject to a previous suspicious activity report.

Where EDD is required, the player may be asked to provide one or more of the following in addition to standard CDD documents:

• Source of Funds (SOF) — documentation evidencing the origin of the funds being used to play on betpandaonline.fr. This may include payslips, employment contracts, bank statements, tax returns, company accounts, evidence of investment returns, inheritance documentation, or other relevant financial records;
• Source of Wealth (SOW) — a broader explanation and supporting documentation of how the player has accumulated their overall wealth, where the total deposited amounts or account activity warrants this level of enquiry;
• Additional identity verification through third-party reference databases or enhanced liveness checks.

The Company will not proceed with processing pending withdrawals on an account subject to EDD until all requested documentation has been reviewed and approved by the AMLCO or a designated senior compliance reviewer.

9. Ongoing Monitoring

KYC is not a one-time exercise. Betpanda applies continuous transaction monitoring across all accounts throughout the lifecycle of the customer relationship. Ongoing monitoring includes:

• Automated flagging of unusual deposit or withdrawal patterns relative to account history;
• Identification of structured transactions — for example, repeated deposits just below internal thresholds — that may indicate deliberate layering;
• Monitoring of win-loss ratios and game type patterns that deviate significantly from the established profile;
• Periodic re-screening of all accounts against updated PEP lists, global sanctions databases (including OFAC, UN, EU, and HM Treasury lists), and adverse media sources;
• Review of cryptocurrency wallet addresses against blockchain analytics tools to identify associations with flagged wallets, darknet markets, mixing services, or other high-risk entities;
• Manual review of accounts escalated by customer support, responsible gaming, or fraud prevention teams.

Where monitoring identifies a material change in an account's risk profile — for example, a sudden significant increase in deposit volumes, or a shift from low-stake casino play to high-frequency high-value sportsbook wagering — the Company will re-verify the account under CDD or EDD as appropriate.

10. Blockchain Analytics and Cryptocurrency-Specific Controls

Because Betpanda is a fully crypto-native platform, our AML controls include a layer of blockchain-specific due diligence that has no direct equivalent in fiat-currency operations. The Company uses third-party blockchain analytics tools to screen incoming and outgoing transactions. These tools assess the risk profile of cryptocurrency wallet addresses and transaction histories, enabling us to identify:

• Funds linked to wallets previously associated with theft, fraud, ransomware, or darknet market activity;
• Funds that have passed through cryptocurrency mixing or tumbling services designed to obscure their origin;
• High-risk exposure scores on deposited assets based on the transaction graph of the source wallet;
• Peer-to-peer exchange or unhosted wallet patterns that indicate elevated anonymisation risk.

Where a deposit is flagged by our blockchain analytics tool as carrying an unacceptable risk score, the Company reserves the right to suspend the account, decline to process any associated withdrawal, and report the matter to relevant authorities. Players are advised that depositing funds from wallets with a high-risk blockchain profile — even if they are personally unaware of the prior activity associated with those funds — may result in account review and potential account restriction.

The use of cryptocurrency mixing services, privacy coins with obfuscated ledgers, or any other method specifically designed to conceal the source or destination of funds is strictly prohibited at betpandaonline.fr. Accounts found to be using such methods will be immediately suspended pending investigation.

11. Prohibited Persons and Jurisdictions

The Company does not accept registrations from or process transactions for:

• Individuals whose names appear on applicable sanctions lists maintained by bodies including the United Nations Security Council, the European Union, the Office of Foreign Assets Control (OFAC), or HM Treasury;
• Individuals or entities associated with designated terrorist organisations;
• Residents of jurisdictions where online gambling is prohibited or where the Company has determined that regulatory risk or financial crime risk is unacceptably high;
• Any person who is under the legal age for gambling in their jurisdiction of residence (and in any case under 18 years of age).

The Company conducts sanctions screening at account registration and on an ongoing periodic basis. Any account that returns a positive or probable match against a sanctions list will be suspended immediately and referred to the AMLCO for urgent review. The Company will not process deposits, withdrawals, bonus credits, or cashback payments — including the Wednesday 10% cashback and daily rakeback — on any account under active sanctions screening review.

12. Suspicious Activity Reporting

All members of Betpanda's operational and support staff are trained to recognise potential indicators of money laundering or other financial crime. Where a staff member identifies behaviour or a transaction that gives rise to suspicion, they are required to file an internal Suspicious Activity Report (SAR) with the AMLCO without delay and without alerting the player concerned ("tipping off"). Tipping off — that is, disclosing to a customer or any third party that a SAR has been filed or that an investigation is under way — is strictly prohibited.

The AMLCO will review each internal SAR and determine whether an external report should be made to a relevant financial intelligence unit or law enforcement authority. Where an external report is made, the Company will cooperate fully with any subsequent investigation and will provide all account records, transaction data, and documentation requested under lawful authority.

Examples of behaviour that may give rise to an internal SAR include but are not limited to:

• A player depositing large amounts of cryptocurrency and immediately requesting withdrawal without meaningful gameplay;
• A player requesting withdrawal to a wallet address different from the one used to deposit funds;
• Rapid sequential deposits across multiple wallets into a single account;
• A player expressing unusual discomfort when asked to complete KYC or provide source of funds documentation;
• A player making unusually low-risk bets with near-certain outcomes in a manner consistent with loss-booking for layering purposes;
• Any pattern of activity inconsistent with the player's stated or apparent profile or financial means.

13. Record Keeping

Betpanda maintains comprehensive records in accordance with this Policy. The following records are retained for a minimum of five years from the date of the relevant transaction or the closure of the account, whichever is later:

• All KYC and EDD documentation supplied by players, including copies of identity documents and supporting financial records;
• All transaction records, including deposit and withdrawal histories with associated wallet addresses, timestamps, and cryptocurrency amounts;
• Internal SARs and records of any external disclosures made to competent authorities;
• Records of all account correspondence relevant to compliance matters;
• Blockchain analytics reports generated in connection with account reviews;
• Records of training completed by compliance and operational staff.

Records are stored securely and accessed only by authorised personnel. They will be disclosed to competent authorities upon receipt of a lawful request and will not be used for any purpose other than AML and KYC compliance, fraud prevention, and the legal obligations of the Company.

14. Staff Training

All customer-facing and compliance personnel at Betpanda receive AML and KYC training commensurate with their role. Training programmes cover:

• Recognition of the stages of money laundering and common red-flag indicators in an online gaming environment;
• Cryptocurrency-specific money laundering typologies, including wallet obfuscation and cross-chain layering;
• Internal SAR procedures and the prohibition on tipping off;
• KYC document collection and verification procedures;
• Applicable sanctions screening obligations;
• Data protection obligations in connection with customer information.

Training is provided at induction and refreshed on a regular periodic basis, or whenever material changes are made to this Policy or to the applicable regulatory framework.

15. Consequences of Non-Compliance for Players

Players who fail to comply with KYC requests, provide false or misleading documentation, or are found to be engaged in money laundering or any other prohibited activity face the following consequences, applied at the Company's discretion and in accordance with our Terms & Conditions:

• Immediate suspension of account access;
• Withholding of all pending withdrawals pending investigation;
• Permanent closure of the account;
• Forfeiture of any bonus balances, including the Wednesday cashback, daily rakeback, welcome bonus, free spins, free bets, and any other promotional credits;
• Reporting of the account and all associated transaction data to relevant financial intelligence units or law enforcement authorities;
• Civil or criminal referral where the evidence supports it.

The Company will not return funds to a player where there is reasonable suspicion that those funds represent the proceeds of crime or terrorist financing. In such cases, funds may be held pending direction from a competent authority.

16. Interaction with Responsible Gaming

Betpanda's AML and KYC programme operates in conjunction with — but is distinct from — our responsible gaming framework. Where a KYC review reveals that a player may be experiencing gambling-related harm, or where a responsible gaming concern is identified during an AML review, the relevant information will be passed to the appropriate team. Players can access responsible gaming tools, including self-exclusion and account limits, through their account settings or by contacting our 24/7 Live Chat or support email. Responsible gaming controls remain in force irrespective of a player's KYC status.

17. Privacy and Data Protection

All personal data collected by Betpanda in connection with this Policy — including identity documents, financial records, and transaction histories — is processed in accordance with our Privacy Policy. Data is collected for the specific purpose of AML and KYC compliance, stored securely, and retained only for as long as required by this Policy and applicable law. Players have rights in relation to their personal data as described in the Privacy Policy. However, certain rights — such as the right to erasure — may be limited where retention is required for regulatory compliance or legal proceedings.

18. Policy Review

This Policy is reviewed periodically by the AMLCO, and formally updated at least annually or whenever material changes occur in the regulatory environment, the Company's product offering, or the typologies of financial crime applicable to the online gaming and cryptocurrency sectors. The current version of this Policy is published on betpandaonline.fr and supersedes all previous versions. Players are encouraged to review this Policy regularly. Continued use of betpandaonline.fr following any update constitutes acceptance of the revised terms.

19. Contact

If you have a question about this Policy or about your account's KYC status, please contact our compliance and support team through one of the following channels:

• Live Chat — available 24/7 directly on betpandaonline.fr
• Email — available via the contact address listed in our Help Centre

All compliance-related correspondence will be handled by trained personnel and, where relevant, escalated to the AMLCO. Response times may vary depending on the complexity of the query, but we aim to acknowledge all compliance-related enquiries within one business day.