Anti-Money Laundering (AML) Policy

Wicked Play
Last updated: 2025

1. Purpose

1.1 Policy Objective

This Anti-Money Laundering Policy (“AML Policy”) outlines the principles, procedures, and controls implemented by Wicked Play (“Wicked Play”, “we”, “us”, or “our”) to prevent:

• Money laundering;
• Terrorist financing;
• Other financial crimes;

1.2 Regulatory Commitment

Wicked Play is committed to full compliance with all applicable:

• AML laws;
• Regulatory requirements;
• International standards;

2. Scope

2.1 Applicability

This AML Policy applies to:

• Wicked Play as a game and software provider;
• Licensed operators, aggregators, and partners using Wicked Play products;
• All business relationships established by Wicked Play;

2.2 Limitation of Responsibility

• Wicked Play does not directly manage player accounts or payment transactions unless explicitly stated;
• Primary AML obligations toward end players rest with licensed operators;

3. Regulatory Framework

3.1 International Standards

Wicked Play’s AML framework is aligned with internationally recognized standards, including:

• Financial Action Task Force (FATF) recommendations;
• Applicable EU Anti-Money Laundering Directives (where relevant);
• Other recognized global AML principles;

3.2 Local Regulations

• Compliance with local AML regulations applicable to Wicked Play and its partners;

4. Risk-Based Approach

4.1 Risk Assessment Criteria

Wicked Play applies a risk-based approach by assessing risks related to:

• Jurisdictions;
• Business partners;
• Products and services;
• Transaction patterns;
• Delivery channels;

4.2 Review Process

• Risk assessments are reviewed periodically;
• Risk profiles are updated when necessary to reflect changing conditions;

5. Partner Due Diligence

5.1 Onboarding Due Diligence

Wicked Play conducts due diligence on operators and business partners prior to onboarding.

5.2 Due Diligence Measures

Due diligence may include:

• Corporate identification and verification;
• Licensing validation;
• Ownership and control structure review;
• Sanctions and watchlist screening;
• Assessment of AML and compliance controls;

5.3 Risk-Based Decisions

• Wicked Play reserves the right to refuse or terminate business relationships where AML risks are deemed unacceptable;

6. Customer Due Diligence (CDD)

6.1 Applicable CDD Measures

Where applicable, Wicked Play applies appropriate CDD measures to business partners, including:

• Verification of legal existence;
• Identification of beneficial owners;
• Understanding the nature and purpose of the business relationship;

6.2 Enhanced Due Diligence (EDD)

• Enhanced Due Diligence (EDD) is applied to higher-risk relationships where required;

7. Transaction Monitoring

7.1 Monitoring Scope

Although Wicked Play does not process player payments directly, it:

• Monitors business-level activity where relevant;
• Reviews technical and operational data for unusual or suspicious behavior;

7.2 Cooperation

• Cooperates with operators and payment service providers when AML-related concerns arise;