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EnglishOperator and Regulatory Identity
Jackpotter is owned and operated by Bravo Entertainment Ltd., a company incorporated in Belize with registration number 000047535 and registered address at Sea Urchin Street, San Pedro Town, Ambergris Caye, Belize.
Jackpotter is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros, under Anjouan Gaming License No. ALSI-202505025-FI1. The licence authorizes B2C gaming activities. The Website offers B2C online gaming products including casino games, sportsbook wagering and Jackpotter Originals, subject to the scope of the licence, approved domains and applicable restrictions.
The purpose of this Policy is to prevent Jackpotter, its accounts, products, payment channels and services from being used for money laundering, terrorist financing, fraud or other financial crime, and to establish documented controls for customer due diligence, enhanced due diligence, transaction monitoring, reporting, record keeping, training and governance.
This Policy applies across all Jackpotter B2C products and services, including online casino games, sportsbook betting and Jackpotter Originals, and to all payment methods and delivery channels made available on the Website, including cryptocurrency where permitted.
• All players and player accounts.
• Directors, officers, employees, contractors and agents involved in onboarding, payments, compliance, fraud prevention or player operations.
• Third-party service providers involved in gaming, payments, KYC, fraud prevention, player onboarding or related compliance functions.
• All authorized Jackpotter domains, brands and URLs operated under the licence.
Outsourcing a control or function does not transfer the operator's responsibility for AML/CTF compliance.
This Policy is maintained with reference to the mandatory AML/CTF standards and guidance issued by Anjouan Licensing Services Inc. / Anjouan Gaming, applicable Anjouan AML/CFT requirements and relevant international standards, including the Financial Action Task Force (FATF) Recommendations.
Where a local law, regulatory direction or binding requirement applicable to a player or transaction imposes a higher standard, Jackpotter may apply the higher standard.
4.1 Management Responsibility
The management of Bravo Entertainment Ltd. is responsible for ensuring that sufficient resources, systems and procedures are maintained to implement this Policy. Material changes to this Policy must be approved through the Company's compliance governance process.
4.2 Compliance Officer
The Company appoints a suitably qualified Compliance Officer responsible for AML/CTF oversight, regulatory liaison, escalation, reporting, maintenance of AML procedures and coordination of training and independent review. The Compliance Officer has direct access to senior management for material compliance matters.
4.3 Staff Responsibilities
Relevant personnel must follow the procedures derived from this Policy, escalate suspicious or unusual activity promptly and maintain confidentiality regarding internal investigations and regulatory reports.
Jackpotter applies a risk-based approach. Controls are proportionate to the money laundering and terrorist financing risks identified through a documented risk assessment, reviewed at least annually and upon material changes to the business, products, payments, jurisdictions or regulatory requirements.
The risk assessment considers, at a minimum:
• Player risk profile, including geography, behaviour, occupation and known funding sources.
• Products and services offered, including casino, sportsbook and proprietary/Originals products.
• Payment methods and delivery channels, including cryptocurrency and payment service providers.
• Jurisdictions involved, including FATF-identified high-risk or otherwise restricted jurisdictions.
• Transaction patterns, account behaviour, fraud indicators and other emerging risks.
Higher-risk relationships are subject to proportionately stronger controls, including Enhanced Due Diligence (EDD), additional source-of-funds review, restrictions or termination where appropriate.
6.1 CDD at Registration
Customer Due Diligence is conducted at player registration. At a minimum, the following information must be collected and recorded before an account is activated:
• Full legal name.
• Valid email address.
• Date of birth.
• Residential address.
The Company may collect additional information necessary for account operation, fraud prevention, sanctions screening, payment processing, responsible gaming or regulatory compliance.
6.2 Identity and Age Controls
Players must be at least 18 years old or the higher legal age applicable in their jurisdiction. Jackpotter may perform electronic verification and may request documentary evidence at any time where needed to establish identity, age, address, payment ownership or risk profile.
EDD is mandatory when any of the following triggers occurs:
• The player makes a first withdrawal request, regardless of the amount.
• Aggregate lifetime deposits reach USD 10,000 or the equivalent in another currency or crypto-asset.
• Elevated risk indicators, unusual behaviour or suspicious activity are identified.
• Additional verification is required by the Company, a payment provider, the regulator or applicable law.
EDD includes, at a minimum:
• A valid government-issued photo identification document.
• A utility bill, bank statement or equivalent reliable document confirming residential address.
• Proof of source of funds where required by the risk assessment or circumstances.
• Any further information reasonably required to establish source of wealth, payment ownership, transaction purpose or the legitimacy of activity.
Where EDD has been triggered but is not complete, withdrawals must not be processed and other financial activity may be restricted where necessary to mitigate risk.
Jackpotter works with payment providers and crypto payment service providers that are expected to maintain appropriate AML/CTF controls. The use of cryptocurrency does not reduce the player's KYC, source-of-funds or transaction-monitoring obligations.
Risk indicators relevant to a crypto-first iGaming environment include, without limitation:
• Structuring or repeated activity designed to avoid verification or reporting thresholds.
• Rapid movement of funds, including deposits followed by withdrawals with limited or economically inconsistent gaming activity.
• Unusual changes in transaction frequency, size, currency or payment channel relative to the player profile.
• Funding or withdrawal patterns suggesting third-party ownership, multiple unrelated payment sources or beneficiary mismatch.
• Repeated use of multiple payment accounts or crypto payment routes without a reasonable explanation.
• Transactions involving or connected to high-risk jurisdictions or other elevated geographic risk.
• Activity inconsistent with known source of funds, source of wealth, occupation or expected player behaviour.
• Unusual, offsetting or otherwise suspicious betting patterns, including patterns potentially designed to convert funds rather than genuinely participate in gaming.
• Risk alerts, adverse information or suspicious indicators supplied by payment, KYC, anti-fraud or other compliance service providers.
Where relevant risk information is available from payment or compliance providers, it may be considered as part of the player risk assessment. Jackpotter may reject, delay, restrict or investigate transactions where required to manage AML/CTF or fraud risk.
Player relationships and transactions are subject to ongoing monitoring designed to identify unusual or suspicious activity relative to the customer profile. Monitoring must be capable of identifying, at a minimum:
• Structuring or threshold avoidance.
• Rapid movement of funds.
• Unusual betting patterns.
• Activity involving high-risk jurisdictions.
Monitoring outcomes may result in additional KYC/EDD, source-of-funds requests, enhanced review, temporary restrictions, account closure or regulatory reporting.
10.1 Internal Escalation
Staff must escalate suspected money laundering, terrorist financing, fraud or other suspicious activity promptly to the Compliance Officer. Players must not be informed that a suspicious activity report or internal escalation has been made where such disclosure is prohibited.
10.2 Suspicious Activity Reports
Suspicious activity must be reported to Anjouan Licensing Services Inc. / Anjouan Gaming within 24 hours of detection, with supporting documentation, and to any other competent authority where required by applicable law or regulatory direction.
10.3 Currency Transaction Reports
Transactions or linked transactions exceeding USD 10,000 or equivalent must be reported in accordance with the applicable Anjouan reporting requirements, whether or not the activity is independently assessed as suspicious.
Jackpotter does not knowingly provide services where online gaming is prohibited or where the Company is not authorized to provide services. The Website maintains jurisdictional restrictions and may use geolocation, KYC information, payment controls and other measures to restrict access. High-risk jurisdictions are subject to enhanced review and may be prohibited based on regulatory requirements, sanctions, FATF risk identification or the Company's risk appetite.
AML-related records are retained securely for a minimum of five years, including CDD and EDD records, transaction records, deposits, wagers and withdrawals, suspicious activity reports, internal compliance reports, audit records and relevant training records. Records must be retrievable and made available to Anjouan Gaming or other competent authorities when lawfully required.
Relevant staff receive AML/CTF training on onboarding, at least annually, and following material regulatory or policy changes. Training covers KYC/EDD, suspicious activity, payment and crypto-related risks, escalation, record keeping, confidentiality and regulatory reporting obligations.
The Company undergoes an independent AML audit annually to assess policy effectiveness, regulatory compliance, internal controls and training. Anjouan Gaming may also conduct inspections, audits or compliance reviews at any time.
Player and compliance data must be protected through appropriate technical and organizational safeguards. Access is limited to personnel and service providers with a legitimate need to know. Data may be disclosed where required for AML/CTF compliance, fraud prevention, regulatory reporting, legal obligations or lawful authority requests.
This Policy is reviewed at least annually and when there is a material change in regulation, products, payment methods, business operations or risk exposure. Breaches may result in internal disciplinary action, account restrictions, termination of business relationships, regulatory reporting and any other action required by law or licensing conditions.
Questions about this Policy may be directed to support@jackpotter.com. Regulatory and compliance matters are handled through the Company's appointed compliance function.