Anti-money Laundering

Introduction

The Anti Money Laundering Policy governs Know Your Customer and related controls for Rkgg. This Policy applies to all activity on the Rkgg Website and establishes the framework for identifying customers, verifying identity, and monitoring transactions in accordance with applicable AML/CFT laws and regulations.

Purposes

The objectives of this Policy are to prevent the use of the Rkgg platform for money laundering and terrorist financing, to enforce compliance with terms and conditions, to deter activity involving minors or other illegal conduct, and to manage legal, financial, and reputational risk to the Company and its customers.

Risk Based Approach

Rkgg applies a risk based methodology aligned with international standards to determine the level of due diligence required. Risk is assessed across three dimensions:

• Geographic risk: considerations include the customer’s country of residence, presence on sanctions lists, and credible sources indicating deficiencies in AML regimes or elevated corruption risk.
• Customer risk: assessment of indicators such as politically exposed persons, adverse regulatory findings, and suspicious behavior patterns.
• Transaction risk: evaluation of the size, frequency, and nature of transactions to identify disproportionate or unusual activity.

Verification and Due Diligence

Verification is conducted when the Company determines a reasonable need to confirm identity and assess risk. Standard verification is triggered by one or more of the following circumstances:

1. Aggregate transactions processed through the Website reach or exceed the equivalent of USD 1,000.
2. The customer presents significant risk of money laundering or terrorist financing.
3. Suspicious behavior or indicators suggesting non-compliance with the Terms and Conditions.
4. Any other scenario where personnel determine that verification is necessary to protect the integrity of the platform.

During Standard Verification, the customer must provide the following documentation, where requested by the Company:

• Identity document: a clear copy or photo of a government issued photo ID (for example a passport or national identity card). If no photo ID is available, a birth certificate may be accepted, provided both corners are visible and accompanied by a photograph of the customer holding the document with the face and certificate clearly visible.
• Proof of address: a recent utility bill or bank statement issued within the last three months displaying the customer’s name and residential address.
• Proof of payment: depending on the deposit method, documentation to establish the source and ownership of funds. Card deposits require a copy of the registered card with the cardholder name, signature, and the first six and last four digits visible; CVV and middle digits must be obscured. If using an electronic wallet, evidence such as the account email on file must be provided. For bank transfers, a recent bank statement showing the origin of funds may be required.
• Selfie or photo of the customer holding the required documents, as well as any other data requested by the Company to verify identity and ownership.
• Additional documents may be requested to confirm address or source of wealth in accordance with the customer’s risk profile.

In certain cases the customer may be asked to engage with the Company’s Support Team via a live communication channel (including video) to complete the verification.

Enhanced Due Diligence

Where a customer is identified as a Politically Exposed Person (PEP) or resides in a high risk jurisdiction, or where risk assessment indicates heightened risk, the Company applies Enhanced Due Diligence (EDD). EDD includes additional data collection and documentation to verify the source of wealth and the origin of funds, ongoing monitoring, and greater scrutiny of the customer relationship. Final approval for Enhanced Verification rests with senior management of the Company.

Definitions used for EDD:

• Politically Exposed Person: a natural person who holds or has held prominent public functions and includes immediate family members and close associates as defined for anti-money laundering purposes.
• High risk jurisdiction: a country identified by credible sources as lacking robust AML/CFT regimes or as a FATF high-risk or otherwise monitored jurisdiction.

Ongoing Monitoring

All customer activity is subject to ongoing monitoring to identify suspicious patterns. The monitoring framework covers:

• Unusual deposit and withdrawal patterns, including use of multiple devices or payment methods within short timeframes.
• Inconsistent geolocation data, device IDs, or account activity that raises risk concerns.
• Any refusal or failure to complete verification or to provide requested information.

Suspicious activity is escalated to the anti-fraud function for risk assessment and, where appropriate, further action including escalation to relevant regulatory authorities in accordance with applicable law.

Transactions Monitoring

All deposits and withdrawals must be verifiable as belonging to the registered customer. The following controls apply:

• Card payments: the cardholder’s name must match the Website account holder’s name.
• Electronic wallets: the wallet account must be the one registered on the customer’s account (email address must match).
• No use of unmapped or anonymous payment instruments. Deposits must be traceable to the customer; withdrawals should not be sent to payment instruments belonging to third parties.
• Where a deposit instrument cannot be reliably traced, the Company may restrict or reverse the related withdrawal to verify ownership.

Record Keeping and Data Protection

Documentation and data collected under this Policy, including verification materials and transaction records, are retained and protected in accordance with applicable AML/CFT laws, data protection regulations, and the Company’s Privacy Policy. The Company complies with the General Data Protection Regulation and other applicable data protection regimes, and retains records for the periods required by law or regulation.

Amendments and Governance

This Policy may be amended at any time to reflect changes in law, regulation, or risk. Registered customers will be notified of changes by email to the address on file. Continued use of the Website after notice constitutes acceptance of the revised Policy.

Cooperation with Authorities

Rkgg reserves the right to report suspicious activity and provide information to competent regulatory, governmental, or law enforcement authorities in accordance with applicable law and regulatory requirements.

Definitions

• Know Your Customer KYC: processes to verify identity and assess risk to prevent financial crime.
• Politically Exposed Person PEP: a natural person who holds or has held prominent public functions and certain family members or close associates as defined in AML frameworks.
• High risk jurisdiction: a country with identified deficiencies in AML/CFT regimes or categorized as high risk by recognized authorities.