KYC Policy

Last modification date: 24.03.2025

1. THE INTRODUCTION.

This Know Your Customer (KYC) Policy (hereinafter referred to as the "Policy") establishes the principles and procedures applied by Udwin B.V. (hereinafter referred to as the "Company," "We," "Us," or "Our"). 

For the purposes of this Policy:

a) The website vox.casino (hereinafter referred to as the "Website").

b) Any natural person holding an account on the Website (hereinafter referred to as the "User").

2. PURPOSE OF THIS POLICY.

The Company enforces the measures outlined in this Policy to:

• Prevent violation of Website`s Terms & Conditions and other applicable documents;

• Prevent Money Laundering (ML), Terrorist Financing (TF), and other financial crimes in accordance with AML/CFT legislation.

• Prohibit underage gambling, ensuring that only individuals of legal age access the Website.

• Detect and prevent fraudulent activities, including cheating, collusion, and identity manipulation.

• Prevent any legal, financial and reputational risks.

3. RISK ASSESSMENT.

The Company implements a risk-based approach, proposed by the Financial Actions Task Force ("FATF") in order to assess each user in the frame of this Policy.

3.1 Country/Geographic Risk

A User’s country of residence/domicile is evaluated based on multiple factors, including but not limited to:

• Whether the country is listed as a “Third Country with Strategic Deficiencies” by the European Commission (under Commission Delegated Regulation (EU) 2016/1675 and its amendments).

• Whether the country is classified as a "High-Risk Jurisdiction Under Increased Monitoring" by the FATF.

• Whether credible sources indicate that the jurisdiction lacks an effective AML/CFT framework, has high corruption levels, or is linked to terrorist financing or other financial crimes.

3.2 Customer Risk

The Company assesses each User's risk profile based on:

• Politically Exposed Person (PEP) status.

• Inclusion in international sanctions lists, such as those imposed by the European Union (EU) and the United Nations (UN).

• Suspicious behavior or activity patterns, including but not limited to:

Excessive deposit activity inconsistent with a User’s known profile.

Multiple device logins within short timeframes.

Device or IP address sharing among multiple accounts.

Unusual transaction patterns indicative of potential fraud or ML/TF risks.

3.3 Transaction Risk

The Company applies risk-based transaction monitoring to:

• Assess whether a User’s spending behavior is consistent with their profile and financial capacity.

• Identify suspicious transactions that may require additional review or Enhanced Due Diligence (EDD) (see "Transaction Monitoring").

• Prevent the use of high-risk or disproportionate transactions to facilitate financial crime.

3.4 Product Risk

The Company evaluates the risk level associated with its gaming products and assesses how their features might be exploited for illicit activities such as money laundering or terrorist financing. Higher-risk products include:

• Large, rapid, or high-value transactions that could facilitate illicit financial flows.

• Products or features that enable anonymity or minimal traceability, increasing the risk of financial crime.

• Game types or betting patterns that may be susceptible to manipulation or abuse.

To mitigate these risks, the Company applies enhanced controls, monitoring, and transaction oversight to ensure its products are not misused for financial crime purposes.

4. VERIFICATION.

The Company applies Standard Verification (or, in legal terms, due diligence) in the following circumstances:

A. The total amount of the transactions, made through the Website by a user, reaches or exceeds a threshold;

B. In the process of the risk assessment is determined, that a user presents a significant risk of money laundering or terrorist financing;

C. The behaviour of the user contains one or more factors, that gives the grounds to suspect a user in the usage of the Website in violation of the Terms and Conditions;

D. In other cases, when the personnel of the Company consider the Verification as a necessary measure.

4.1 Documents Required for Standard Verification

When applying Standard Verification, the Company may require Users to submit the following documents:

Identification Document – A copy or photo of a valid government-issued ID, such as a passport, national ID card, or driver’s license.

Payment Card Verification – A photo of the payment card used or intended for deposits. The cardholder’s name must match the User’s name registered on the Website. To protect sensitive data, the CVV code and all but the first six and last four digits of the card number must be hidden.

Selfie with Documents – A photo of the User holding their identification document to confirm authenticity.

Proof of Address – A utility bill, phone bill, or official bank statement, issued within the last three (3) months, confirming the User’s residential address.

Financial Documents – In certain cases, the Company may request bank statements, tax assessment notices, or an official letter from the User’s employer to verify financial activity.

Handwritten Verification – Photo of the user, holding a list of paper with a necessary data, written by hand: a) the e-mail of the user, used when registering an account; and b) the date of the photo request and the confirmation code.

Additional Documentation – Any other documents or information deemed necessary based on risk assessment, regulatory requirements, or specific circumstances.

Live Verification – In some cases, the Company may require the User to complete a voice or video call with the Website’s Support Team to further authenticate their identity.

5. ADDITIONAL VERIFICATION FOR PEPS AND USERS FROM HIGH-RISK JURISDICTIONS.

The Company applies additional Verification measures in the following circumstances:

A) The user is a Politically Exposed Persons in the meaning of the article 3(9) of the 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 or terrorist financing or the user is the member of the family of the Politically Exposed Person.

Under the article 3(9) of the abovementioned Directive, the Politically Exposed Person is a natural person who is or who has been entrusted with prominent public functions and includes the following:

(a) heads of State, heads of government, ministers and deputy or assistant ministers;

(b) members of parliament or of similar legislative bodies;

(c) members of the governing bodies of political parties;

(d) members of supreme courts, of constitutional courts or of other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances;

(e) members of courts of auditors or of the boards of central banks;

(f) ambassadors, chargés d'affaires and high-ranking officers in the armed forces;

(g) members of the administrative, management or supervisory bodies of State-owned enterprises.

(h) directors, deputy directors and members of the board or equivalent function of an international organisation.

The abovementioned list excludes middle-ranking or more junior officials.

The article 3(10) of the Directive 2015/849 defines "family member" as:

(a) the spouse, or a person considered to be equivalent to a spouse, of a politically exposed person;

(b) the children and their spouses, or persons considered to be equivalent to a spouse, of a politically exposed person.

B) The country of user`s residence (jurisdiction) is defined as the "Third country with the strategic deficiencies" by the European Commission (in accordance with the Commission Delegated Regulation (EU) 2016/1675 or any amending regulations) and/or the country of user`s jurisdiction is defined as "high-risk and other monitored jurisdiction" by the FATF;

C) In other cases, when the Company considers this procedure as a necessary measure.

D) The country of user`s residence (jurisdiction) is defined by the credible source as lacking an appropriate Anti-Money Laundering and Counter Terrorist Financing regime, or identified by credible sources as having a significant level of corruption or providing support to terrorists or terrorist activities.

When applying additional verification, the Company requires to submit the document(s) or data on the source of user`s wealth in accordance with his/her country’s legal and regulatory requirements. Additionally, in case of additional verification, the final approval on the verification shall be done by senior management of the Company.

The Company reserves the right to collect additional verification data of the user for the purposes of this Policy. Additionally, in cases when: a) a user refuses to pass verification; and/or b) the Company has ample grounds to suppose, that a user uses the Website for illegal purposes, and the user does not provide evidence to the contrary, the Company may inform proper regulatory/governmental/financial authorities on this case.

6. ACTIVITY MONITORING.

All operations of the users are checked on the absence of the suspicious activity. Suspicious activity includes, but not limited to:

• Usage of several cards through different payment agents, proposed by the Company;

• Obtaining a specific error code when making a payment;

• Usage of payment cards, issued by different emitters, that are located in different regions;

• Usage of different payment instruments within a short term (cards, electronic wallets, banking transactions);

• Opposition or unwillingness of the user to verification of his/her account or payment instrument or his/her account as a whole;

• Mismatch of the geolocation of user`s key elements (citizenship/residency, mobile carrier provider, IP address geolocation, BIN number of the card etc.);

• Principal opposition to any phone or video call, non-provision by the user of his/her photo of him/her with the identification document in hands (upon request);

• Matching of the user`s device ID (telephone, computer, tablet) with the device ID of another account in our system.

In case of any suspicious activity, mentioned above, this issue shall be directed to the antifraud department in order to evaluate a risk of this user and to conduct further actions. The antifraud department shall evaluate this issue and further direct it to the relevant department for further consideration.

7. TRANSACTIONS MONITORING.

All the transactions of users on withdrawal and deposits shall comply with the following requirements:

• If the transaction is made by using a payment card, the name of the holder shall be the same as the name of the Website account owner. It means that any usage of third-party payment card is prohibited.

• If the transaction is made by using an electronic wallet, this wallet`s electronic mail must be the same, that was used by a user when registering an account on the Website.

In case if a deposit is made from the payment instrument, placement of funds to which is unavailable, the withdrawal shall be made to the user`s banking account, or to another payment instrument - where it will be possible to reliably ascertain that this payment instrument really belongs to the user in question.

The Company does not accept payments from the anonymous payment instruments (cryptocurrencies, anonymous wallets etc.).The Company does not withdraw funds, that were deposited by the user, to the payments instrument of another user.

8. RECORD-KEEPING OF USER`S DOCUMENTS AND DATA.

The documents and data, obtained during the Verification, and other financial data (including transaction data and its supportive evidence) shall be stored, kept, shared and protected in strict compliance with:

The Legislation of the European Union on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, namely the Directive (EU) 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 or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC;

The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("General Data Protection Regulation" or "GDPR");

The Limitation of Legal Proceedings act (Law 66(I)/2012) of the Republic of Cyprus;

The Privacy Policy of the Website.

9. AMENDMENTS AND MODIFICATIONS.

This Policy may be modified or amended at any time, at the sole discretion of the Company. It is sole responsibility of the user to review this Policy periodically for new changes and amendments. Registered users will be notified on any changes to this Policy via e-mail address, which was used when registering an account on the Website. Any continued usage of the Website after the notification has been sent shall be considered as a fact that user have read and accepted the changes to the Policy.