This Anti-Money Laundering and Know Your Customer Policy ("Policy") sets out the obligations of Magico Games N.V., operator of betninja (accessible at betninja-login.nl), with respect to the prevention of money laundering, terrorist financing, and related financial crime. betninja operates under licence ALSI-082309007-FI4 issued by the Anjouan Gaming Authority. All players, transactions, and accounts on betninja-login.nl are subject to the procedures described below.

1. Introduction and Purpose

Money laundering is the process by which criminally obtained funds are introduced into the legitimate financial system and disguised to conceal their true origin. Terrorist financing involves the provision or collection of funds intended to support acts of terrorism. Both activities are serious criminal offences that cause significant harm to individuals, communities, and the integrity of regulated markets.

Magico Games N.V. is committed to ensuring that betninja-login.nl is not used as a vehicle for money laundering, terrorist financing, fraud, or any other financial crime. This Policy establishes a framework of controls — including customer due diligence, transaction monitoring, record-keeping, and reporting — designed to detect, deter, and disrupt such activity in accordance with our licensing obligations and applicable international standards, including the recommendations of the Financial Action Task Force (FATF).

Compliance with this Policy is mandatory for all employees, contractors, and third parties acting on behalf of Magico Games N.V. in connection with betninja-login.nl. Players who do not meet our verification requirements, or who trigger our risk controls, may have their accounts suspended, restricted, or closed, and funds may be withheld pending investigation or reported to the relevant authorities.

2. Scope

This Policy applies to:

• All natural persons registering or holding an account on betninja-login.nl;
• All deposits, withdrawals, bonus activations, and financial transactions processed through betninja-login.nl, regardless of payment method or currency;
• All payment methods accepted by betninja, including but not limited to Visa, Mastercard, iDEAL, MiFinity, Apple Pay, Google Pay, Revolut, Skrill, Neteller, Trustly, Klarna, Paysafecard, AstroPay, PayPal, and cryptocurrencies (BTC, ETH, USDT, LTC, XRP, SOL, and DOGE);
• All currencies processed on the platform, including EUR, USD, GBP, AUD, and CAD, as well as the supported cryptocurrency denominations.

3. Regulatory Framework

betninja is operated by Magico Games N.V. under Anjouan Gaming Authority licence ALSI-082309007-FI4. Our AML and KYC obligations are derived from this licence and the regulatory standards it incorporates, as well as internationally recognised frameworks including FATF Recommendations, relevant EU Anti-Money Laundering Directives (applied by reference as best-practice standards), and applicable data protection legislation governing the processing of personal information collected during verification.

Where we identify conduct or transactions that give rise to suspicion of money laundering or terrorist financing, we are obliged to file a Suspicious Activity Report (SAR) or equivalent report with the competent authorities and to refrain from "tipping off" the subject of that report.

4. Money Laundering Risk in Online Gaming

Online casino environments present particular money laundering risks, including but not limited to: depositing funds and requesting withdrawal without meaningful gameplay ("round-tripping"); exploiting bonus structures to convert criminal funds into bonus winnings; using multiple accounts, shared devices, or third-party payment methods to obscure the source of funds; and layering transactions across different payment methods or currencies. betninja operates robust controls to identify and mitigate each of these risks.

5. Know Your Customer (KYC) Policy

5.1 Identity Verification — When It Is Required

betninja applies a risk-based approach to customer due diligence. Identity verification may be triggered at any of the following points:

• Upon registration, at betninja's discretion and depending on the player's risk profile;
• Before the first withdrawal is processed;
• When cumulative deposits or withdrawals reach thresholds that indicate enhanced due diligence is appropriate;
• When a transaction or pattern of behaviour triggers our monitoring systems;
• When a player requests a withdrawal and has not previously completed verification;
• At any time betninja considers it necessary to satisfy our regulatory obligations.

A player whose KYC verification is pending may be permitted to continue playing but will not be able to withdraw funds until verification is satisfactorily completed. betninja aims to process submitted KYC documentation within 24 hours in most cases. Players are encouraged to complete verification proactively to avoid delays when requesting a payout.

5.2 Standard KYC Documents

To satisfy standard Customer Due Diligence (CDD) requirements, players must provide the following documentation:

• Proof of Identity (POI): A valid, unexpired government-issued photo ID — such as a national identity card, passport, or driving licence. The document must clearly show the player's full legal name, date of birth, photograph, and document number. Copies must be clear, unobstructed, and in colour.
• Proof of Address (POA): A recent document — dated within the last three months — confirming the player's residential address. Acceptable documents include a utility bill (gas, electricity, water, or internet), bank statement, or official government correspondence. The document must show the player's full name and current address.
• Proof of Payment Method (POPM): Confirmation that the payment method used belongs to the player. For bank cards this may mean a photograph or screenshot showing the card number (partially masked), name, and expiry date. For e-wallets or cryptocurrency wallets, a screenshot of the account or wallet showing the player's name and relevant account details may be required. For crypto transactions, betninja may request confirmation of the originating wallet address.

5.3 Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be applied where a player presents a higher risk profile, including but not limited to the following circumstances:

• The player is identified as a Politically Exposed Person (PEP) — that is, an individual who holds or has held a prominent public function — or is a close associate or family member of a PEP;
• The player is located in, or transacting from, a high-risk or sanctioned jurisdiction as identified by FATF or other relevant bodies;
• The player's transaction volumes are unusually high relative to their stated profile;
• The player's gameplay pattern is inconsistent with normal recreational activity;
• There are inconsistencies between declared information and verified documentation;
• The player has previously triggered a suspicious activity alert.

Where EDD is applied, betninja may request one or more of the following in addition to standard KYC documents:

• Source of Funds (SOF) documentation — such as recent payslips, tax returns, bank statements covering a defined period, or evidence of business income;
• Source of Wealth (SOW) documentation — evidence explaining how the player accumulated their overall wealth, particularly where large sums are being deposited or withdrawn;
• A declaration of PEP status, signed by the player;
• Additional identification documents or notarised copies of existing documents.

betninja reserves the right to restrict account activity — including suspending deposits, withdrawals, or gameplay — while EDD is being conducted. We may decline to proceed with a business relationship where EDD requirements cannot be satisfied.

5.4 Beneficial Ownership

betninja does not permit accounts to be opened or operated on behalf of a third party. All registered accounts must be held in the genuine name of the individual operating them, and all funds deposited must originate from a payment method registered in the account holder's own name. Third-party deposits and withdrawals are strictly prohibited.

Where a player is found to be using an account on behalf of another person, or to be receiving or forwarding funds on behalf of a third party, the account will be suspended immediately and a report may be filed with the relevant authorities.

5.5 Screening Against Sanctions and Watchlists

All registered players are screened against applicable sanctions lists, including those maintained by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), and other relevant bodies. This screening occurs at the point of registration, upon submission of KYC documentation, and on an ongoing basis during the account relationship. Players who appear on applicable sanctions lists will have their accounts frozen and funds reported or dealt with in accordance with the applicable legal obligations. betninja will not process any transaction for a sanctioned individual or entity.

6. Transaction Monitoring

6.1 Overview

betninja's compliance team monitors all financial activity on the platform on an ongoing basis. Our monitoring programme is designed to detect patterns of behaviour that may be indicative of money laundering, fraud, or other financial crime. Monitoring applies to all deposits, withdrawals, bonus activity, and gameplay patterns, across all payment methods and currencies available on betninja-login.nl.

6.2 Indicators of Suspicious Activity

Our systems and compliance personnel are trained to identify a wide range of red-flag indicators, including but not limited to:

• Depositing funds and withdrawing a similar amount with minimal or no gaming activity — commonly referred to as "round-tripping";
• Multiple deposits from different payment methods in a short period;
• Rapid cycling between different currencies or payment instruments, including switching between fiat and cryptocurrency;
• Withdrawal requests that significantly exceed deposited amounts, particularly where the winnings are not consistent with the gameplay pattern recorded;
• Attempts to use accounts registered to different individuals to pool funds;
• Providing inconsistent, vague, or evasive responses to KYC or Source of Funds requests;
• Use of cryptocurrency wallets associated with mixing services, darknet markets, or other high-risk entities;
• Transaction volumes that are disproportionate to the player's stated occupation, income, or profile;
• Unusual or repeated deposits just below thresholds that might otherwise trigger enhanced review (structuring);
• Account activity that suggests the account is being used by multiple individuals.

6.3 Transaction Limits and Their AML Relevance

betninja applies the following withdrawal and deposit limits as part of its overall financial control framework:

These limits support our ability to monitor financial flows effectively. Any request to increase limits beyond the standard thresholds will require enhanced verification, including Source of Funds documentation, before the higher limits are applied.

6.4 Cryptocurrency Transactions

betninja accepts deposits and withdrawals in Bitcoin (BTC), Ethereum (ETH), Tether (USDT), Litecoin (LTC), XRP, Solana (SOL), and Dogecoin (DOGE). Cryptocurrency transactions carry specific AML risks due to their pseudonymous nature and the speed at which they can move. betninja applies the following controls to cryptocurrency activity:

• All cryptocurrency deposits and withdrawals are screened using blockchain analytics tools to identify wallet addresses associated with high-risk activity, including darknet markets, mixing or tumbling services, ransomware, or sanctioned entities;
• Players transacting in cryptocurrency are subject to the same KYC and EDD requirements as fiat-currency players;
• Withdrawals will only be processed to wallets that can be verified as belonging to the account holder. betninja reserves the right to request confirmation of wallet ownership before processing a crypto withdrawal;
• Cryptocurrency received from flagged or high-risk wallet addresses may be held pending investigation, and a report may be filed with the appropriate authorities.

7. Reporting Suspicious Activity

Where betninja's compliance team identifies activity that gives rise to a reasonable suspicion of money laundering or terrorist financing, a Suspicious Activity Report (SAR) will be filed with the relevant financial intelligence unit or competent authority as required by our licence and applicable law. Such reports are filed in strict confidence. betninja is legally prohibited from disclosing to the player — or to any other person not directly involved in the investigation — that a report has been made or that an investigation is underway. This prohibition is commonly referred to as the "tipping-off" restriction and applies to all betninja staff without exception.

In connection with a SAR filing or ongoing investigation, betninja may be required to freeze or delay the processing of withdrawals, suspend account access, or retain funds pending instruction from the relevant authority. Players affected by such measures will be informed only to the extent permitted by law.

8. Record Keeping

betninja retains all records obtained as part of our KYC and AML procedures for a minimum of five years from the date the customer relationship ends, or from the date of the relevant transaction — whichever is the later. Records retained include, but are not limited to:

• Copies of all identity and address verification documents submitted by players;
• Records of all transactions processed through betninja-login.nl, including deposits, withdrawals, bonus activations, and wagering activity;
• Records of any Source of Funds or Source of Wealth documentation obtained;
• Records of all SARs filed and internal compliance decisions made in connection with them;
• Records of screening results against sanctions and watchlists;
• Correspondence relevant to any compliance investigation.

All records are stored securely and in accordance with applicable data protection law. Access is restricted to authorised compliance personnel and, where required, regulatory or law enforcement authorities.

9. Player Obligations

By registering and maintaining an account on betninja-login.nl, players agree to the following obligations:

• To provide accurate, complete, and up-to-date information at the time of registration and throughout the account relationship;
• To promptly supply any documentation or information requested by betninja as part of KYC, EDD, or transaction monitoring procedures;
• To only deposit funds from payment methods registered in their own name and to only withdraw to accounts or wallets they personally own;
• Not to engage in, or attempt to engage in, any activity that constitutes money laundering, terrorist financing, fraud, or any other financial crime;
• To notify betninja promptly of any material change in their circumstances, including changes to their source of income or residential address;
• To accept that betninja may delay or suspend withdrawals, or restrict account access, where verification or investigation requires it.

Failure to comply with these obligations may result in the suspension or permanent closure of the player's account, the forfeiture of bonus funds, the withholding of pending withdrawals, and/or the reporting of the player's activity to the relevant authorities.

10. Responsible Gaming and AML Interaction

betninja's responsible gaming framework and our AML controls operate in parallel and reinforce one another. Unusual patterns of deposit behaviour, chasing losses, or escalating stakes can be indicators of both problem gambling and potential money laundering. Where our monitoring identifies behaviour that gives rise to concern in either respect, our compliance and safer gambling teams will work together to apply the appropriate response, which may include account review, affordability checks, deposit limit adjustments, or account closure.

Players who wish to set deposit limits, loss limits, cool-off periods, or self-exclude are encouraged to contact our support team via 24/7 live chat or at [email protected]. Details of our Responsible Gaming tools are set out in our dedicated Responsible Gaming Policy, available on betninja-login.nl.

11. Staff Training and Internal Controls

All employees and contractors of Magico Games N.V. involved in the operation of betninja-login.nl who have access to customer data, financial records, or transaction information receive regular training on:

• The identification and reporting of suspicious activity;
• KYC and EDD procedures and documentation requirements;
• Sanctions screening and PEP identification;
• The legal prohibition on tipping off;
• Record-keeping obligations;
• Developments in money laundering typologies relevant to the online gaming industry.

betninja maintains a designated Money Laundering Reporting Officer (MLRO) who is responsible for overseeing compliance with this Policy, reviewing and filing SARs, liaising with regulatory and law enforcement authorities, and keeping this Policy up to date in response to regulatory developments.

12. Policy Review and Updates

This Policy is reviewed at least annually, and additionally whenever there is a material change in our regulatory obligations, business model, or the risk environment in which we operate. The current version of this Policy is published on betninja-login.nl and supersedes all previous versions. Players are encouraged to review this Policy periodically. Continued use of betninja-login.nl constitutes acceptance of the Policy as currently published.

13. Contact

If you have questions about this Policy, your verification status, or any aspect of our AML or KYC procedures, please contact us through one of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via betninja-login.nl
• Email: [email protected]

Please include your registered account username and a brief description of your query. For document submissions, our support team will provide secure upload instructions. Do not send sensitive identity documents as unencrypted email attachments unless specifically instructed to do so by a betninja compliance agent.