KYC POLICY – INOUT GAMES

Effective date: June 1, 2025
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros

IOGr B.V. (“Company”, “InOut Games”, “we”, “our” “our team”, or “us”) is the licensed operator and provider of the website https://inoutgames.com/ (the “Website”), including all associated subdomains, tools, and services.

This KYC and AML Policy describes how the Company applies Know Your Customer (KYC) and Anti-Money Laundering (AML) standards to all B2B clients. The purpose is to prevent the misuse of our services for money laundering, terrorism financing, or other unlawful purposes.

This document is binding for all partners, operators, resellers, and service providers engaging with the Company.

1. Purpose and Scope

The Policy sets minimum standards for identifying, verifying, and monitoring clients. It ensures compliance with applicable regulations of Anjouan and international AML/CTF frameworks.

2. Risk-Based Approach (RBA)

We apply a risk-based model for onboarding and continuous monitoring. Each client is evaluated based on:

Jurisdiction of registration and operations.
Ownership structure and beneficial ownership.
Nature of products and services offered.

Depending on the risk profile, the Company applies either Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD).

3. Due Diligence Requirements

3.1. Customer Due Diligence (CDD)

Clients must provide:

Certificate of incorporation or trade register extract (dated within 3 months).
Articles/Memorandum of Association.
Proof of business address (utility bill or bank statement).
Corporate structure chart showing shareholders and ultimate beneficial owners (UBOs).
ID documents for directors and UBOs (>25% ownership).
Proof of residence for UBOs (recent utility bill or bank statement).

3.2. Enhanced Due Diligence (EDD)

EDD applies where clients are considered high risk, e.g.:

Operating from a high-risk jurisdiction (e.g., FATF black/grey list).
Complex or opaque ownership.
Controlled by Politically Exposed Persons (PEPs).
Past regulatory or compliance issues.

Additional requirements may include:

Proof of source of funds and source of wealth.
Independent AML audit reports.
Gaming license documents.
Background and reputational checks.

4. Ongoing Monitoring

Reviews are conducted periodically (minimum annually) or upon any material change.
Suspicious activity may result in service suspension pending investigation.
Clients must inform the Company of ownership or structural changes.

5. PEP and Sanctions Screening

All directors and UBOs are screened against PEP and sanctions databases (UN, EU, OFAC, and trusted third-party lists).
Matches are subject to further investigation and may trigger rejection or EDD.

6. Recordkeeping

All KYC and AML records are stored for a minimum of six (6) years after termination of the business relationship, in compliance with Anjouan regulations.

7. Restricted Jurisdictions

The Company will not onboard clients registered in or owned by persons from:

FATF high-risk or non-cooperative jurisdictions.
Countries subject to UN, EU, or OFAC sanctions.
Union of the Comoros (for white-label clients targeting the same jurisdiction).
Any other territory restricted by the Anjouan Offshore Financial Authority.

8. Failure to Comply

Failure to provide KYC documentation, or providing false information, may result in:

Refusal of onboarding.
Suspension of services.
Termination of partnership.
Filing of reports to relevant regulators.

9. Amendments

This Policy may be amended to reflect updates in regulation or industry practice. Clients will be informed in writing of any material changes.