This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Winnerz, operated by Feature Buy Ltd. and accessible at winnerznl.nl, to detect, prevent, and report financial crime in accordance with the conditions of our licence issued by the Government of the Autonomous Island of Anjouan (licence number ALSI-202410039-FI2). All players, staff, and third parties interacting with Winnerz are expected to understand and comply with the standards described below.

1. Introduction and Purpose

Winnerz is committed to operating a safe, transparent, and legally compliant gaming environment. Money laundering — the process by which illegally obtained funds are made to appear legitimate — and terrorist financing represent serious threats to the integrity of the financial system and to the reputation of the online gaming industry. This Policy establishes the framework that Winnerz applies to combat those threats.

The objectives of this Policy are to:

• Establish robust customer due diligence procedures that allow us to verify who our players are before and during their relationship with winnerznl.nl;
• Identify and monitor transactions and behavioural patterns that may indicate money laundering, fraud, or terrorist financing;
• Ensure that suspicious activity is escalated, investigated, and reported to the relevant competent authorities without delay;
• Maintain adequate records to support any regulatory audit, investigation, or enforcement action;
• Protect Winnerz, Feature Buy Ltd., and our genuine players from the harm caused by financial crime.

This Policy applies to every account registered on winnerznl.nl, regardless of the currency used, the payment method chosen, or the volume of play.

2. Regulatory Framework

Winnerz is licensed and regulated by the Government of the Autonomous Island of Anjouan under licence number ALSI-202410039-FI2. Feature Buy Ltd. holds this licence and bears full regulatory responsibility for compliance with its conditions, including those relating to anti-money laundering, counter-terrorist financing, and customer due diligence.

In addition to its licence conditions, Winnerz aligns its procedures with internationally recognised AML/CFT standards, including those published by the Financial Action Task Force (FATF). Where our licence conditions impose requirements that are stricter than those standards, the licence conditions take precedence. Where FATF guidance exceeds the explicit licence requirements, Winnerz applies the higher standard as a matter of good practice.

3. Definitions

• AML — Anti-Money Laundering: the set of laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.
• CFT — Counter-Financing of Terrorism: measures designed to identify, disrupt, and prevent the financing of terrorist activities.
• KYC — Know Your Customer: the process of verifying the identity of a customer and understanding the nature of their activity.
• CDD — Customer Due Diligence: the standard level of identity and activity verification applied to all customers.
• EDD — Enhanced Due Diligence: additional verification measures applied to customers who present a higher risk.
• PEP — Politically Exposed Person: an individual who holds, or has held within the past twelve months, a prominent public function, or who is a close associate or family member of such a person.
• SAR — Suspicious Activity Report: an internal or external report filed when a transaction or pattern of behaviour raises concern about potential money laundering or terrorist financing.
• MLRO — Money Laundering Reporting Officer: the designated individual within Feature Buy Ltd. responsible for receiving, assessing, and where necessary reporting suspicious activity.
• Source of Funds (SoF) — the origin of the specific funds used by a customer on winnerznl.nl.
• Source of Wealth (SoW) — the origin of the customer's total accumulated wealth.

4. Risk-Based Approach

Winnerz applies a risk-based approach to AML and KYC compliance. This means that the intensity of due diligence measures applied to any individual account is proportionate to the level of money laundering or terrorist financing risk that the account presents. Accounts assessed as presenting a lower risk receive standard CDD measures. Accounts assessed as presenting a higher risk receive EDD measures, which may include requests for additional documentation and more frequent review of transaction history.

Risk assessments consider factors including, but not limited to:

• The country or jurisdiction of the customer's residence;
• The payment methods and currencies used — including cryptocurrency transactions via Bitcoin (BTC) and XRP (Ripple), which are accepted on winnerznl.nl;
• The volume, frequency, and value of deposits and withdrawals relative to the player's stated profile;
• Whether the customer is a PEP or is associated with a PEP;
• Any adverse media, sanctions screening results, or other intelligence available to Winnerz;
• Unusual betting patterns or withdrawal requests that are inconsistent with normal gaming behaviour.

Risk assessments are not static. They are reviewed on a continuous basis as new information becomes available and as the customer's activity on winnerznl.nl evolves.

5. Know Your Customer (KYC) Procedures

5.1 Account Registration

Every individual wishing to play on winnerznl.nl must create a personal account. During registration, players are required to provide accurate and complete information, including their full legal name, date of birth, country of residence, and a valid email address. By submitting this information, the player confirms that it is truthful and undertakes to keep it current.

Winnerz reserves the right to impose restrictions on an account — including suspension of withdrawals and suspension of bonus access — until identity verification is completed to our satisfaction. Creating an account using false information, operating multiple accounts, or permitting a third party to use your account constitutes a breach of our Terms and Conditions and may result in permanent closure of the account and forfeiture of any funds held therein.

5.2 Standard Customer Due Diligence (CDD)

Standard CDD is applied to all accounts on winnerznl.nl. It must be completed before any withdrawal is processed. Winnerz may also request CDD documents at the point of registration, before a bonus is credited, or at any time during the customer relationship where we deem it necessary.

To complete standard CDD, players will typically be required to provide:

• Proof of Identity (POI): A valid, government-issued photographic document such as a passport, national identity card, or driving licence. The document must be current (not expired), clearly legible, and show the player's full name and date of birth.
• Proof of Address (POA): A document confirming the player's residential address, such as a utility bill, bank statement, or official government correspondence. The document must be dated within the last three months and display the player's full name and address.
• Proof of Payment Method: Where required, confirmation that the player is the legitimate owner or authorised user of the payment method used — for example, a screenshot of a crypto wallet, a bank statement, or a card image (with the middle eight digits obscured for security).

Documents submitted for KYC purposes must be clear, unedited originals or certified copies. Winnerz may use automated identity verification technology and/or manual review to assess submitted documents. We reserve the right to request alternative or additional documents where the materials provided are insufficient to complete verification.

5.3 Enhanced Due Diligence (EDD)

Where an account is assessed as presenting an elevated risk, Winnerz will apply EDD measures in addition to the standard CDD requirements. EDD may be triggered by, but is not limited to, the following circumstances:

• The customer is identified as, or associated with, a PEP;
• The customer is resident in, or the funds originate from, a jurisdiction identified by FATF as high-risk or subject to increased monitoring;
• The customer's deposits or withdrawal requests are high in value or inconsistent with their declared profile;
• Transactions involve cryptocurrency in amounts that, combined with other risk factors, raise concern;
• Suspicious activity indicators are present (see Section 7);
• The customer has reached withdrawal thresholds that internally trigger a higher level of review.

EDD measures may include one or more of the following:

• A request for Source of Funds documentation — for example, recent payslips, bank statements, a letter from an accountant, or evidence of a business transaction;
• A request for Source of Wealth documentation — for example, evidence of employment history, business ownership, investments, or an inheritance;
• A face-to-face or video verification call;
• Additional screening against PEP, sanctions, and adverse media databases;
• Increased frequency of account and transaction monitoring;
• Escalation to the MLRO for assessment and, where appropriate, filing of a SAR.

Winnerz will not process a withdrawal request where EDD has been triggered until the EDD process is satisfactorily completed. As noted in our payment information, most withdrawals move instantly post-KYC, but where enhanced checks are in progress, the timeline will extend accordingly. We appreciate the patience of customers who are asked to provide additional documentation and confirm that legitimate requests are processed as promptly as possible.

5.4 Ongoing Monitoring

Completing KYC at the time of first withdrawal does not conclude our obligations. Winnerz conducts ongoing monitoring of all active accounts throughout the customer relationship. This includes:

• Continuous review of transactions for consistency with the customer's known profile;
• Periodic re-screening of accounts against PEP and sanctions lists;
• Periodic requests for updated documentation where the original documents have expired or where the customer's circumstances appear to have changed materially;
• Automated flagging of unusual transaction patterns for manual review.

Where ongoing monitoring reveals new information that affects the customer's risk profile, Winnerz will update its assessment and apply the appropriate level of due diligence accordingly.

6. Payment Methods and Cryptocurrency Considerations

Winnerz accepts deposits and withdrawals via bank transfer, Bitcoin (BTC), XRP (Ripple), and other methods as listed in our cashier. The flat deposit commission is €1 and the fixed withdrawal fee is €2, regardless of method. The weekly withdrawal limit is €2,500 and the monthly withdrawal limit is €10,000.

Cryptocurrency deposits and withdrawals carry specific AML considerations. Winnerz applies the following controls to crypto transactions:

• Players using Bitcoin or XRP must confirm that the wallet used is in their own name and under their sole control. Third-party wallet transactions are not permitted.
• For XRP deposits, players must include the correct destination tag within three calendar days of initiating the transaction. Failure to do so may cause the transaction to become unrecoverable, and Winnerz will not be able to credit funds that cannot be attributed to a verified account.
• Transactions must be sent on the native blockchain only. Bridged networks are not supported. This requirement exists partly for technical reasons and partly because cross-chain bridging can obscure the origin of funds, which is inconsistent with our AML obligations.
• Where the value of a crypto transaction, or a series of crypto transactions, triggers an EDD review, Winnerz may request blockchain analytics information or on-chain evidence of the wallet's legitimate origin.
• Winnerz does not accept deposits from wallets that have been flagged by blockchain analytics tools as associated with darknet markets, mixer or tumbler services, sanctions, or other high-risk activity. Such deposits will be returned, less any applicable fees, and the account will be subject to review.

Players should be aware that the 5x turnover requirement described in our payment terms — under which failure to meet the requirement before withdrawal results in a 20% fee — is a player-protection and anti-abuse measure rather than an AML control, though it operates alongside our AML framework to deter rapid deposit-and-withdrawal cycles that may indicate layering activity.

7. Suspicious Activity — Recognition and Reporting

7.1 Indicators of Suspicious Activity

Winnerz trains its compliance team to recognise a range of behavioural and transactional indicators that may suggest money laundering, terrorist financing, or fraud. These include, but are not limited to:

• Depositing significant funds and withdrawing them rapidly with minimal or no gaming activity — sometimes referred to as "pass-through" behaviour;
• Placing unusually large bets inconsistent with the customer's typical pattern, particularly on low-margin events or games, with rapid withdrawal of any resulting balance;
• Requesting withdrawals to a different payment method or account from the one used for deposits;
• Depositing via multiple methods in rapid succession or making multiple deposits that individually fall below a threshold but cumulatively represent a significant amount;
• Providing inconsistent or implausible information during KYC or EDD;
• Transferring funds between accounts or requesting that winnings be paid to a third party;
• Reluctance or refusal to provide KYC or EDD documentation without a plausible explanation;
• Use of cryptocurrency wallets associated with high-risk activity as identified by blockchain analytics;
• Repeated deposits that appear to test transaction limits before a larger transaction is attempted;
• Patterns of play that appear designed to generate artificial turnover to satisfy the 5x deposit turnover requirement without genuine wagering intent.

7.2 Internal Reporting

Any member of Winnerz's compliance or operations team who identifies a suspicious activity indicator is required to report it promptly to the MLRO. Internal reports must be made without alerting the customer concerned — it is a criminal offence in most jurisdictions to "tip off" a customer that they are the subject of a suspicious activity investigation.

The MLRO will assess each internal report and determine whether it warrants escalation to an external SAR filed with the competent authority under our Anjouan licence, or with any other relevant authority. The MLRO maintains a log of all internal reports received, the outcome of each assessment, and, where applicable, the details of any external filing.

7.3 Account Freezing and Delays

Where Winnerz has reasonable grounds to suspect that funds held in an account may be the proceeds of criminal activity, or that processing a withdrawal may constitute money laundering, we reserve the right to:

• Suspend or freeze the account pending investigation;
• Delay or refuse a withdrawal request;
• Request further documentation from the player;
• Retain funds pending instructions from a competent authority or the outcome of a legal process.

Winnerz will not be liable for any loss suffered by a player as a result of a good-faith account suspension or withdrawal delay where that action was taken in accordance with this Policy and our legal obligations.

8. Sanctions Screening

Winnerz screens all players and payment details against applicable international sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and HM Treasury. Screening takes place at account registration, at KYC review, at the point of any material change to the customer's profile, and on a periodic basis throughout the customer relationship.

Where a match is identified — whether a confirmed match or a potential match requiring further investigation — the account is immediately suspended and the matter is escalated to the MLRO. Winnerz does not knowingly accept funds from, or make payments to, any individual or entity on a designated sanctions list. Any funds received from a sanctioned party will be held and dealt with in accordance with the instructions of the relevant competent authority.

9. Politically Exposed Persons (PEPs)

Winnerz identifies and applies EDD to all customers who are PEPs, or who are immediate family members or known close associates of PEPs. Being a PEP does not automatically disqualify an individual from holding an account on winnerznl.nl. However, given the elevated risk that PEPs present — by virtue of their potential access to public funds and their susceptibility to corruption — Winnerz applies a higher standard of due diligence to their accounts as a matter of course.

EDD for PEPs will always include Source of Wealth verification and will involve explicit approval by the MLRO or senior management before the account is activated or significant transactions are processed. PEP status is reassessed periodically, as the relevant risk period may extend for at least twelve months after an individual has left a position that conferred PEP status.

10. Record Keeping

Winnerz retains all KYC documentation, transaction records, internal suspicious activity reports, and correspondence relevant to AML/CFT compliance for a minimum of five years from the date of the relevant transaction or from the date of the end of the customer relationship, whichever is the later. Records are stored securely in a format that allows them to be retrieved and produced to a competent authority upon lawful request without undue delay.

Records maintained include:

• Copies of all identity and address verification documents submitted by customers;
• Records of all CDD and EDD assessments, including the basis on which risk ratings were assigned;
• Full transaction histories — deposits, withdrawals, and gaming activity — for every account;
• Internal SAR logs and, where applicable, records of external filings;
• Sanctions screening results and PEP assessments;
• Staff training records.

11. Staff Training

Feature Buy Ltd. ensures that all personnel involved in customer-facing, compliance, payments, or fraud-prevention functions receive appropriate AML/CFT training. Training covers the legal and regulatory framework applicable to winnerznl.nl, the requirements of this Policy, how to recognise suspicious activity indicators, how to make an internal report to the MLRO, and the prohibition on tipping off.

Training is provided to new staff before they begin work in a relevant role and is refreshed at regular intervals and whenever material changes to this Policy or the applicable regulatory framework occur. Records of all training delivered are maintained as part of our compliance documentation.

12. Player Responsibilities

Players on winnerznl.nl bear a number of responsibilities under this Policy:

• Providing accurate, complete, and up-to-date information at registration and throughout the customer relationship;
• Submitting KYC and EDD documentation promptly when requested, in a clear and legible format;
• Ensuring that all funds deposited originate from a legitimate source and are from an account or wallet in the player's own name;
• Not using the Winnerz platform to deposit, hold, or withdraw funds on behalf of a third party;
• Not attempting to circumvent our transaction limits, verification requirements, or any other AML/CFT control;
• Notifying Winnerz promptly if their circumstances change in a way that is material to their account — for example, if they acquire PEP status.

Players who fail to meet these responsibilities, or who are found to have provided false information, may have their account suspended or permanently closed, their bonus entitlements forfeited, and any funds under investigation withheld pending resolution. Winnerz may also be required to report such conduct to the relevant authorities.

13. Interaction with the Responsible Gaming Framework

Winnerz's AML and KYC framework operates alongside, and is complementary to, our responsible gaming commitments. Certain behaviours that may indicate problem gambling — such as rapidly escalating deposit volumes, erratic betting patterns, or repeated failed withdrawal requests — may also constitute risk indicators for AML purposes. Where our monitoring systems flag an account for either reason, the compliance and responsible gaming teams coordinate their response to ensure that the player receives appropriate support while our legal obligations are also met.

Players who wish to self-exclude, set deposit limits, or activate a bonus block may do so by contacting our support team via Live Chat or email. Support is available in English, German, and Finnish. These tools are part of our broader commitment to player protection and do not affect any compliance review that may be ongoing independently.

14. Bonus and Promotional Integrity

Winnerz's bonus and promotional structure — including the welcome package of up to €700, the 141-level loyalty programme, the Winnerz Wheel Spin, and weekly cashback — is designed for genuine player engagement. Bonus abuse and bonus manipulation are treated as forms of fraud and will be investigated under the same framework as other financial crime indicators.

Where a player appears to be exploiting promotional mechanics — for example, by depositing to claim a bonus and immediately withdrawing without genuine play, or by structuring bets to generate artificial turnover — the account will be reviewed by the compliance team. The 25x wagering requirement (applied to bonus plus deposit), the maximum bonus winnings cap of €1,000 from cashback and promotional rewards, and the 0% contribution of table games, live dealer, baccarat, roulette, jackpot games, and video poker to wagering are all conditions that apply to our bonuses for legitimate player protection and commercial reasons. Attempts to circumvent them may constitute fraud and will be treated accordingly.

15. Withdrawal Limits and Monitoring Thresholds

The weekly withdrawal limit on winnerznl.nl is €2,500 and the monthly withdrawal limit is €10,000. These limits serve both as commercial parameters and as AML monitoring thresholds. Withdrawal requests at or approaching these limits, or patterns of behaviour designed to keep transactions below them, may trigger additional review.

The minimum withdrawal amounts — €25 for crypto and other methods, €50 via bank transfer — and the fixed fees associated with each transaction are applied consistently to all accounts. The €2 fixed withdrawal fee and €1 fixed deposit commission are not waived under any circumstances as part of AML monitoring; transparency of fee structures supports our ability to detect anomalous transaction costs that may indicate attempts to manipulate the payment process.

16. Policy Review and Updates

This Policy is reviewed at least annually by the MLRO and senior management of Feature Buy Ltd., and is updated whenever required by changes to our licence conditions, applicable law, FATF guidance, or internal risk assessments. The current version of this Policy is published on winnerznl.nl and supersedes all previous versions. Players are encouraged to review the Policy periodically. Continued use of winnerznl.nl following a material update constitutes acceptance of the revised Policy.

17. Contact and Escalation

If you have a question about this Policy or about the KYC process as it applies to your account, please contact the Winnerz support team via Live Chat or email. Support is available in English, German, and Finnish. For queries relating to the status of a withdrawal pending KYC completion, please have your account details and any reference numbers ready to assist the team in responding promptly.

Any concerns about financial crime relating to winnerznl.nl may be addressed to the MLRO via the compliance contact details available on request from the support team. Winnerz takes all such reports seriously and will investigate promptly and confidentially.