AML & KYC Policy

1. Introduction

PNCL N.V. ("PNCL") is committed to preventing the use of our platform for money laundering, terrorist financing, or any other financial crime. This policy sets out our obligations and procedures under applicable anti-money laundering legislation and the requirements applicable to companies incorporated under the laws of Costa Rica.

We operate a robust Know Your Customer ("KYC") programme to verify the identity of all customers and to assess the risks associated with their activities. Compliance with this policy is mandatory for all customers, employees, and third parties acting on our behalf.

2. Customer Verification (KYC Requirements)

All customers are required to verify their identity before they can withdraw funds, or where we determine it necessary for compliance purposes. Verification may also be requested at any time during the customer relationship. The following documents are accepted:

2.1 Proof of Identity

One of the following valid, government-issued documents:

• Passport (biographical data page)
• National identity card (front and back)
• Driving licence with photograph (front and back)

Documents must be current (not expired), clearly legible, and show your full name, date of birth, and photograph.

2.2 Proof of Address

One of the following documents dated within the last 3 months:

• Utility bill (gas, electricity, water, or internet)
• Bank or credit card statement
• Government-issued letter or official correspondence

2.3 Proof of Payment Method

PNCL may request evidence that you are the rightful owner of the payment method used for deposits (e.g., a screenshot of your e-wallet account, a photo of your bank card showing only the last four digits).

2.4 Selfie / Liveness Check

We may request a live selfie or a photograph of you holding your identity document for biometric verification purposes.

3. Source of Funds

For customers with significant transaction volumes or where we identify elevated risk indicators, we may request evidence of the legitimate source of funds used for gambling. Acceptable evidence includes:

• Recent payslips or employment contract
• Bank statements demonstrating income
• Tax returns or self-assessment documentation
• Evidence of business ownership or dividends
• Evidence of inheritance, property sale, or investment proceeds

Failure to provide satisfactory source of funds information may result in restriction of your account and refusal to process withdrawals until the matter is resolved.

4. Transaction Monitoring

PNCL operates an automated transaction monitoring system that flags unusual patterns, including but not limited to:

• Large cash-equivalent transactions or frequent deposits just below reporting thresholds.
• Deposits immediately followed by withdrawal requests without meaningful play activity.
• Multiple accounts being used with the same or linked payment methods or devices.
• Transaction patterns inconsistent with the stated purpose of gambling for entertainment.
• Deposits from or withdrawals to high-risk jurisdictions.

Flagged transactions are reviewed by our compliance team. Where a concern cannot be resolved, we are required to file a Suspicious Activity Report (SAR) with the relevant financial intelligence unit and may be prohibited from informing you of this action ("tipping-off" restrictions apply).

5. Prohibited Jurisdictions and Sanctions

PNCL does not accept customers from jurisdictions where online gambling is prohibited, or from countries that are subject to comprehensive international sanctions (including but not limited to those maintained by the UN, EU, US OFAC, and UK OFSI). We screen all customers against relevant sanctions lists at onboarding and on an ongoing basis.

If you are identified as a Politically Exposed Person (PEP) or as a close associate of a PEP, enhanced due diligence measures will apply, including senior management approval before your account is activated or maintained.

6. Record Keeping

PNCL retains KYC documentation and transaction records for a minimum of 5 years from the end of the customer relationship, or such longer period as required by applicable law. Records are stored securely and access is restricted to authorised personnel on a need-to-know basis.

7. Reporting Obligations

Where PNCL suspects, knows, or has reasonable grounds to know or suspect that a transaction is related to money laundering or terrorist financing, we are legally obligated to report this to the competent authorities in Costa Rica and, where applicable, to international financial intelligence units. We cooperate fully with law enforcement investigations.

8. Account Suspension and Fund Freezing

PNCL reserves the right to suspend your account and withhold funds where:

• You fail to complete KYC verification within the required timeframe.
• We have reasonable grounds to suspect money laundering, fraud, or other financial crime.
• We are required to do so by a competent authority or pursuant to applicable law.
• You are identified on a sanctions list.

Funds may be frozen pending investigation and, where required, may be reported or transferred to relevant authorities.

9. Contact

For KYC-related queries, please contact our compliance team at support@parify.bet. Please include your account username and a description of your query. We will respond within 5 business days.