Anti-money Laundering

Scope and Purpose

Hd77 is committed to preventing money laundering and the financing of terrorism in accordance with applicable anti-money laundering and countering financing of terrorism (AML/CFT) laws and regulations. This policy applies to all Hd77 customers and Hd77 staff and governs customer due diligence, ongoing monitoring, suspicious activity reporting, and related recordkeeping.

Regulatory Framework and Program Governance

Hd77 implements an internal AML program designed to comply with the applicable AML/CFT requirements. The program includes risk assessment, customer due diligence (CDD), ongoing monitoring, escalation, and cooperation with competent authorities. Hd77 maintains records of customer identities and transactions as required by law and internal policy.

Risk-Based Approach

Hd77 applies a risk-based methodology to determine the level of due diligence, monitoring, and escalation. Risk factors include customer type, geographic exposure, product or service usage, and transaction patterns. The greater the risk, the more robust the controls and monitoring applied.

Customer Due Diligence Phases

• Default CDD: standard identity verification and basic due diligence for typical customers and ordinary transactions.
• Simplified CDD: applied in lower-risk situations; reduced document requirements; ongoing monitoring remains in effect.
• Enhanced CDD (ECDD): applied for high-risk customers or transactions; requires additional documents and intensified ongoing monitoring.

Information and Documentation for Verification

Hd77 may request information and documents to verify identity, residence, and the legitimacy of funds. The minimum elements and the verification framework are as follows:

• Minimum identification information: full name; permanent residential address; date of birth; place of birth; nationality; government-issued identity number or passport/ID details.
• Verification documents: government-issued photo ID (e.g., passport or national ID); proof of address (e.g., utility bill, bank statement) not older than six months; additional documents may be required for higher-risk scenarios.
• Verification modalities: Hd77 may verify identity and lawful possession of payment means by photos, videos, or specialized software, or by other methods consistent with applicable law.
• Source of funds and wealth: documentation or information explaining the origin of funds used for deposits and the origin of total assets, as applicable to the level of risk.
• Employment and income: information on occupation, employer, and annual income may be requested in higher-risk situations.

Source of Funds, Source of Wealth

Source of funds refers to the funds used to fund the transaction at hand. Source of wealth refers to the origin of the customer’s total assets. Hd77 may require disclosure and supporting documentation to verify both, particularly where risk indicators are present.

Timing and Access to Services

Hd77 may restrict access to services while verification information or documents are being obtained. Customers will receive a reasonable deadline for document submission. In most cases, documents must be provided within 30 calendar days from the request. Failure to provide verifiable information may result in limited or suspended access or termination of the relationship.

Payment Details and Prohibition on Third-Party Payments

Hd77 does not accept third-party payments. Deposits and other payments must be initiated from bank accounts, cards, e-wallets, or other payment methods registered in the customer’s name. If Hd77 determines that a payment originated from a third party, Hd77 may suspend or terminate the account and void winnings; Hd77 is not responsible for funds transferred from non-name-held accounts.

Ongoing Monitoring and Re-Verification

Hd77 conducts ongoing monitoring of customer activity and performs periodic reviews. Re-verification may be triggered by changes in risk factors, material changes to information, or the emergence of new regulatory requirements. Updated information may be requested as a condition of continued service.

Suspicious Activity Reporting

Hd77 monitors transactions for indicators of money laundering or terrorist financing and reports any suspicious activity to the competent authorities in compliance with applicable laws. All relevant records, including customer identities and transactions, are retained for the periods required by law and Hd77’s internal policy.

Data Protection, Recordkeeping, and Privacy

Hd77 processes personal data in accordance with applicable privacy laws. Hd77 maintains secure records of customer identities, due diligence, and transactions, and restricts access to information to authorized personnel in the performance of duties.

Senior Management Approval and High-Risk Relationships

Hd77 may require explicit senior management approval to establish or continue certain high-risk business relationships or product lines. Decisions are documented and supported by the risk assessment and due diligence findings.

Policy Updates and Customer Obligations

Hd77 reserves the right to amend this policy to reflect changes in laws, regulations, or risk assessments. Material updates will be communicated, and continued use of Hd77 services constitutes acceptance of the revised policy. Customers may be required to re-verify details following material updates or regulatory changes.

Contact and Guidance

For guidance on providing documentation or questions about this policy, customers should contact Hd77 Support via the official channels available within the Hd77 platform. This policy is to be read together with Hd77’s Terms and Conditions and other applicable policies.