Axionplay

Last updated: 05.10.2026

1. Introduction

1.1. The website https://axionplay.online (the “Website”) is owned and operated by 3-102-056694, a limited liability company registered in COSTA RICA with company registration number 3-102-056694, with registered address at Province 01 San José, Canton 01 San José, Mata Redonda, Las Vegas Neighborhood, two-story blue building diagonal to La Salle High School, operating under the brand AxionPlay (the “Company”, “we”, “us”).

1.2. This Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Policy (the “AML Policy”) sets out the measures the Company takes to prevent its services from being used for money laundering, terrorist financing, proliferation financing and sanctions evasion.

1.3. The Company has zero tolerance for financial crime. It will not enter into or continue any relationship where it cannot apply the measures in this policy, and it will cooperate fully with the Anjouan Offshore Finance Authority, the Costa Rican authorities and law enforcement.

1.4. This policy applies to all users, all transactions, all business partners and all directors, employees and contractors of the Company (“Staff”). It is approved by the director of the Company and reviewed at least once a year.

2. Legal Framework

2.1. The Company complies with:

2.1.1. the Computer Gaming Licensing Act 007 of 2005 of the Autonomous Island of Anjouan, the conditions of its licence and the AML/CFT requirements of the Anjouan Offshore Finance Authority;

2.1.2. the anti-money laundering and counter-terrorist financing laws applicable in Anjouan and the Union of the Comoros;

2.1.3. the laws of the Republic of Costa Rica, including Law No. 7786 on Narcotics, Psychotropic Substances, Drugs of Unauthorised Use, Related Activities, Money Laundering and Terrorist Financing, as amended in particular by Laws No. 8204 and No. 9449;

2.1.4. the Recommendations of the Financial Action Task Force (FATF);

2.1.5. the sanctions of the United Nations Security Council and, as good practice, the sanctions lists of the European Union, the United Kingdom and the United States (OFAC).

2.2. Where requirements differ, the Company applies the stricter standard.

3. Definitions

3.1. Money laundering means any act that conceals or disguises the criminal origin of funds or property, usually in three stages: placement (introducing criminal funds into the financial system), layering (moving funds to hide their origin) and integration (returning the funds to the economy as apparently legitimate).

3.2. Terrorist financing means providing or collecting funds, from legal or illegal sources, with the intention or knowledge that they will be used for terrorist acts or by terrorists or terrorist organisations.

3.3. Politically exposed person (“PEP”) means a person who holds or has held a prominent public function, such as a head of state, minister, member of parliament, senior judge, senior military officer, ambassador, central bank board member or senior executive of a state-owned company, together with their family members and close associates.

3.4. Source of funds means the origin of the specific funds used for a transaction. Source of wealth means the origin of a user’s total wealth.

4. Money Laundering Risks in Online Gaming

4.1. The Company recognises that online casinos can be misused, for example by:

4.1.1. depositing criminal funds and withdrawing them as apparent winnings with little or no play;

4.1.2. using stolen cards or payment accounts of other persons;

4.1.3. colluding with other players to transfer value between accounts;

4.1.4. using multiple accounts or money mules;

4.1.5. using prepaid instruments or cryptocurrencies to hide the origin of funds;

4.1.6. using low-risk betting patterns, such as betting on both red and black, to move funds with minimal loss.

5. Responsibilities

5.1. The director of the Company, Renārs Stenkevics, is ultimately responsible for AML compliance. The director approves this policy and the risk assessment, appoints the Money Laundering Reporting Officer and reviews AML reports at least every quarter.

5.2. The Money Laundering Reporting Officer (“MLRO”) is Renārs Stenkevics, who is responsible for:

5.2.1. implementing and maintaining the AML programme;

5.2.2. receiving internal reports of suspicious activity and deciding on reports to the authorities;

5.2.3. approving relationships with PEPs and high-risk users;

5.2.4. overseeing verification, screening and transaction monitoring;

5.2.5. organising AML training for Staff;

5.2.6. preparing quarterly and annual AML reports.

5.3. The MLRO has access to all records and Staff and may block any account or transaction. Compliance decisions take priority over commercial considerations.

5.4. A Deputy MLRO will be appointed as the Company grows, to act for the MLRO during absence. Until then, the MLRO arranges cover through a qualified external compliance adviser during any absence.

5.5. All Staff must follow this policy, complete training and report any suspicion to the MLRO without delay.

6. Risk-Based Approach

6.1. The Company carries out a written business-wide risk assessment before launch, at least annually, and before launching any new product, market or payment method.

6.2. Every user receives a risk rating of low, medium or high, based on:

6.2.1. customer risk: PEP status, adverse media, occupation, account behaviour;

6.2.2. geographic risk: country of residence, nationality, IP location, FATF grey-listed countries;

6.2.3. product risk: high-limit tables, live games, peer-to-peer games;

6.2.4. payment risk: prepaid instruments, cryptocurrencies, frequent changes of payment method;

6.2.5. transaction risk: size and speed of deposits, ratio of deposits to play, withdrawal patterns.

6.3. Low-risk users are reviewed every 24 months, medium-risk users every 12 months, and high-risk users every 6 months.

7. Prohibited Users and Restricted Countries

7.1. The Company does not accept:

7.1.1. persons under 18;

7.1.2. persons or entities on any sanctions list used by the Company, or entities owned or controlled by them;

7.1.3. anonymous accounts or accounts in false names;

7.1.4. companies, trusts or other legal entities;

7.1.5. users who refuse to provide due diligence information;

7.1.6. payments from or through shell banks or unlicensed payment providers.

7.2. The Company does not accept users who are residents of, or who access the Website from, any of the following countries and territories:

• Australia
• Austria
• Belgium
• Costa Rica
• Cuba
• France and its overseas departments and territories
• Germany
• Israel
• Italy
• Netherlands and its territories (including Aruba, Curaçao, Sint Maarten and the Caribbean Netherlands)
• Ontario (Canada)
• Portugal
• Spain
• Syria
• Union of the Comoros (including the Autonomous Island of Anjouan)
• United Kingdom (including the Isle of Man, Jersey and Guernsey)
• United States of America and its territories and possessions
• Crimea and the temporarily occupied regions of Donetsk, Luhansk, Zaporizhzhia and Kherson (Ukraine)
• All FATF blacklisted countries (High-Risk Jurisdictions subject to a Call for Action), currently the Democratic People’s Republic of Korea (North Korea), Iran and Myanmar
• Any country subject to comprehensive United Nations sanctions
• Any other jurisdiction deemed prohibited by the Anjouan Offshore Finance Authority, or where online gambling is prohibited by law

7.3. Users from countries on the FATF list of Jurisdictions under Increased Monitoring (“grey list”) are subject to enhanced due diligence. The internal country list is updated within 5 business days of each FATF publication.

8. Customer Due Diligence

8.1. Customer due diligence is carried out in accordance with our KYC Policy and includes:

8.1.1. identifying the user and verifying their identity, date of birth and address;

8.1.2. verifying ownership of payment methods;

8.1.3. screening against sanctions, PEP and adverse media lists;

8.1.4. understanding the expected level of activity;

8.1.5. ongoing monitoring of the account.

8.2. Basic checks and screening are carried out at registration. Full verification is completed before the first withdrawal, and in any case when total lifetime deposits exceed EUR 2,000 (or currency equivalent).

8.3. Verification is also required whenever there is a suspicion of money laundering or terrorist financing, regardless of any threshold, or when there are doubts about information previously provided.

8.4. If due diligence cannot be completed, no further deposits, play or withdrawals are allowed, the MLRO considers whether a report to the authorities is required, and the account is closed.

9. Enhanced Due Diligence

9.1. Enhanced due diligence applies to:

9.1.1. PEPs, their family members and close associates;

9.1.2. high-risk users;

9.1.3. users connected to FATF grey-listed or other high-risk countries;

9.1.4. users whose deposits exceed EUR 5,000 in 30 days or EUR 20,000 in 12 months;

9.1.5. users whose activity does not match their profile.

9.2. Enhanced due diligence includes:

9.2.1. obtaining evidence of source of funds and source of wealth, such as payslips, tax returns, bank statements covering at least three months, company accounts, sale contracts or inheritance documents;

9.2.2. confirming the user’s occupation and employer;

9.2.3. approval of the MLRO before continuing the relationship;

9.2.4. a video interview where needed;

9.2.5. manual review of withdrawals and review of the account at least every 6 months.

9.3. A former PEP remains subject to enhanced due diligence for at least 12 months after leaving office, and for longer if the MLRO considers it necessary.

10. Sanctions Screening

10.1. All users are screened against the UN, EU, UK and US sanctions lists at registration, whenever their details change, and daily thereafter.

10.2. Possible matches are reviewed within 1 business day. False positives are documented with reasons.

10.3. If a match is confirmed, the Company immediately freezes the account and funds, blocks all transactions, reports to the competent authorities without delay and does not inform the user of the reason.

10.4. Business partners, including payment providers, game providers and affiliates, and their beneficial owners, are also screened.

11. Payments

11.1. Deposits and withdrawals are accepted only through payment methods registered in the user’s own name.

11.2. Withdrawals are returned to the payment method used for depositing wherever possible (closed-loop principle).

11.3. Cash and third-party payments are not accepted.

11.4. A single deposit may not exceed EUR 2,000 (or currency equivalent) unless approved by the Company.

11.5. The number of payment methods per account is limited, and new methods may require verification.

11.6. Cryptocurrency transactions, where offered, are screened with blockchain analytics for links to darknet markets, mixers, sanctioned addresses and fraud. High-risk transactions are blocked and reviewed.

11.7. Users may not transfer funds directly to other users.

11.8. Payment providers are used only after due diligence on their licence and AML controls.

12. Transaction Monitoring

12.1. All transactions are monitored by automated rules and manual review. The rules are reviewed at least once a year.

12.2. Monitoring scenarios include:

12.2.1. withdrawals requested after wagering less than the amount deposited;

12.2.2. deposits over EUR 5,000 in 24 hours or EUR 10,000 in 7 days;

12.2.3. several deposits just below verification or limit thresholds;

12.2.4. use of many payment methods in a short period, or repeated declined deposits;

12.2.5. deposits inconsistent with the user’s occupation or income;

12.2.6. accounts sharing devices, IP addresses, payment details or addresses;

12.2.7. repeated play between the same users with one-sided losses;

12.2.8. log-ins from Restricted Countries or through VPNs or proxies;

12.2.9. sudden high activity on a long-inactive account.

12.3. Before every withdrawal, the account activity and balance are checked to confirm that the amount results from genuine play.

12.4. Alerts are reviewed within 2 business days and the outcome is recorded.

13. Red Flags

13.1. Staff must also be alert to:

13.1.1. reluctance to provide information or documents;

13.1.2. documents that appear altered or forged;

13.1.3. requests to pay winnings to another person;

13.1.4. questions about how to avoid checks or reporting thresholds;

13.1.5. a user acting on instructions from another person;

13.1.6. activity that makes no economic sense;

13.1.7. adverse media about criminal activity.

14. Reporting of Suspicious Activity

14.1. Any Staff member who knows or suspects money laundering, terrorist financing or sanctions evasion must report it to the MLRO immediately, and in any case within 1 business day, using the internal report form.

14.2. The MLRO investigates each report and decides whether to file a suspicious transaction report with the competent authorities, including the Anjouan Offshore Finance Authority and, where Costa Rican law applies, the Financial Intelligence Unit (UIF) of the Costa Rican Drug Institute (ICD). The decision and reasons are recorded.

14.3. The Company follows all instructions of the authorities to freeze funds or to continue or end a relationship.

14.4. Staff must not tell the user or any other person that a report has been made or is being considered (“tipping off”). The user is told only that the account is under compliance review.

14.5. Staff who report in good faith are protected from retaliation.

15. Staff Screening and Training

15.1. Staff are screened before hiring, including identity checks, references, sanctions screening and, where permitted, criminal record checks.

15.2. Staff and their close family members may not hold accounts on the Website.

15.3. All Staff receive AML training on joining and at least once a year. Compliance, payments and customer support Staff receive additional training on their roles. Training records are kept.

16. Business Partners and Affiliates

16.1. The Company carries out due diligence on all payment providers, game providers, platform providers, verification providers and affiliates before working with them.

16.2. Affiliates must not target Restricted Countries or minors, and their traffic is monitored for fraud and linked accounts.

17. Record Keeping

17.1. The Company keeps identification documents, screening results, account files, transaction and game records, internal reports, suspicious transaction reports and training records for at least 5 years after the end of the relationship, or longer if required by law or the regulator.

17.2. Records are kept securely and can be provided to the authorities promptly on request.

18. Independent Audit

18.1. The AML programme is audited by an independent auditor at least once every 12 months. Findings and actions are reported to the director.

19. Contact

19.1. Questions about this policy may be sent to axionplay.support@gmail.com.