1. Purpose

JujuVegas.com is committed to preventing its website, services, payment facilities, and business relationships from being used for money laundering, fraud, sanctions evasion, or other unlawful financial activity.

This Anti-Money Laundering Policy ("AML Policy") establishes the principles and procedures JujuVegas uses to identify, assess, prevent, detect, and respond to money laundering risks.

JujuVegas applies a risk-based approach to AML compliance and seeks to maintain appropriate controls based on the nature and level of money laundering risk associated with its customers, transactions, payment methods, jurisdictions, and services.

2. Scope

This AML Policy applies to:

• All JujuVegas customers and account holders;
• Directors, officers, employees, contractors, and agents;
• Payment service providers and relevant third parties;
• Business partners and service providers where applicable;
• Deposits, withdrawals, payments, transfers, bonuses, and other financial transactions conducted through JujuVegas;
• All jurisdictions in which JujuVegas lawfully provides its services.

Where applicable law imposes stricter AML requirements, JujuVegas will comply with the stricter applicable requirements.

3. AML Commitment

JujuVegas has a zero-tolerance approach toward the use of its services for money laundering or other unlawful financial activity.

The Company will take reasonable and proportionate measures to:

1. Identify customers;
2. Verify customer identities where required;
3. Assess customer risk;
4. Understand the expected nature of customer activity;
5. Monitor transactions and account activity;
6. Identify unusual or suspicious activity;
7. Conduct enhanced due diligence for higher-risk customers;
8. Maintain appropriate records;
9. Restrict or terminate accounts where appropriate;
10. Report suspicious activity to competent authorities where legally required.

4. Risk-Based Approach

JujuVegas recognizes that money laundering risks can vary depending on the customer, jurisdiction, payment method, transaction activity, and other circumstances.

The Company therefore applies a risk-based approach when determining the level of AML controls required.

4.1 Customer Risk

Customer risk may be assessed using factors such as:

• Identity and verification status;
• Country of residence;
• Nature and expected level of account activity;
• Transaction history;
• Payment methods used;
• Multiple or linked accounts;
• Previous compliance concerns;
• Unusual account behaviour;
• Source of funds where required;
• Other relevant risk indicators.

4.2 Geographic Risk

JujuVegas may consider the AML risks associated with countries and jurisdictions, including:

• Jurisdictions identified as presenting elevated money laundering risks;
• Jurisdictions subject to applicable financial restrictions or sanctions;
• Jurisdictions where online gambling or JujuVegas services are prohibited;
• Jurisdictions presenting increased regulatory or financial crime risks.

4.3 Transaction Risk

Transactions may receive increased scrutiny where they involve:

• Unusually large deposits or withdrawals;
• Rapid deposits followed by withdrawals;
• Activity inconsistent with the customer's normal account behaviour;
• Multiple payment instruments;
• Third-party payment methods;
• Frequent changes in payment methods;
• Unusual transaction patterns;
• Attempts to avoid applicable transaction or verification requirements.

5. Know Your Customer (KYC)

JujuVegas may require customers to provide appropriate identification and verification information before permitting certain activities or transactions.

Depending on applicable law and the customer's risk profile, information may include:

• Full legal name;
• Date of birth;
• Residential address;
• Country of residence;
• Government-issued identification;
• Contact information;
• Payment information;
• Source of funds information where required;
• Additional information reasonably required for AML purposes.

JujuVegas may use reliable and independent sources to verify customer information.

If the required verification cannot be satisfactorily completed, JujuVegas may restrict the account, delay or refuse certain transactions, suspend the account, or terminate the customer relationship, subject to applicable law.

6. Customer Due Diligence (CDD)

JujuVegas will apply appropriate Customer Due Diligence measures based on the customer's AML risk.

CDD may include:

• Identifying the customer;
• Verifying customer identity;
• Understanding the expected purpose and nature of the account;
• Assessing relevant AML risk factors;
• Monitoring customer activity;
• Obtaining additional information where necessary.

The extent of CDD may vary depending on the customer's risk level.

7. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be applied where a customer, transaction, payment method, or jurisdiction presents an increased money laundering risk.

EDD may include:

• Additional identity verification;
• Proof of residential address;
• Source-of-funds verification;
• Source-of-wealth verification where appropriate;
• Additional transaction information;
• Additional supporting documentation;
• Increased transaction monitoring;
• Management or compliance approval.

Higher-risk customers may be subject to more frequent reviews and enhanced monitoring.

8. Source of Funds

JujuVegas may request information or documentation concerning the source of funds used for deposits or other transactions where required by applicable law or where the customer's activity presents increased AML risk.

Examples of supporting documentation may include:

• Bank statements;
• Employment or income information;
• Business income records;
• Investment documentation;
• Sale-of-asset documentation;
• Other reliable evidence demonstrating the legitimate origin of funds.

Failure to provide satisfactory information may result in transaction restrictions or account action, subject to applicable law.

9. Source of Wealth

Where appropriate, JujuVegas may request information regarding the source of a customer's overall wealth.

This may be relevant where the customer's transaction activity or financial profile presents elevated AML risk.

Supporting documentation may include information relating to:

• Employment;
• Business ownership;
• Investments;
• Property;
• Inheritance;
• Other legitimate sources of wealth.

10. Transaction Monitoring

JujuVegas may use automated systems, manual reviews, or a combination of both to monitor customer activity.

Monitoring may include:

• Deposit amounts and frequency;
• Withdrawal activity;
• Deposit-to-withdrawal patterns;
• Payment-method changes;
• Account activity;
• Multiple accounts;
• Unusual transaction behavior;
• Activity inconsistent with the customer's established profile;
• Other AML risk indicators.

Monitoring parameters and thresholds may be adjusted according to the Company's risk assessment and applicable legal requirements.

11. Suspicious Activity

Potential indicators of money laundering may include:

• Depositing funds and quickly withdrawing them without reasonable explanation;
• Using JujuVegas primarily to move funds rather than for legitimate gaming activity;
• Using payment instruments belonging to unrelated third parties;
• Providing inconsistent, false, or unverifiable information;
• Operating multiple accounts for potentially improper purposes;
• Attempting to circumvent AML or verification controls;
• Unusual transaction patterns without an apparent legitimate explanation;
• Activity inconsistent with the customer's known financial profile;
• Attempts to conceal the origin or ownership of funds.

These examples are not exhaustive.

A single indicator does not necessarily mean that money laundering has occurred. JujuVegas will assess the customer's overall circumstances and available information.

12. Suspicious Transaction Reporting

Where JujuVegas identifies activity that creates a reasonable suspicion of money laundering or another reportable financial crime, the Company will assess whether a report must be submitted to the appropriate competent authority.

Reports will be submitted in accordance with applicable laws and regulatory requirements.

JujuVegas will maintain appropriate confidentiality concerning suspicious activity investigations and reports where required by law.

13. Sanctions and Restricted Parties

JujuVegas may conduct screening against applicable sanctions and restricted-party lists as part of its broader financial crime controls.

Where a potential match or restricted transaction is identified, JujuVegas may restrict the relevant account or transaction while the matter is reviewed.

Confirmed matches or prohibited transactions will be handled in accordance with applicable laws and regulatory requirements.

14. Third-Party Payment Methods

JujuVegas may restrict or prohibit the use of third-party payment methods where required by its AML controls or applicable law.

Customers may be required to demonstrate that payment instruments used to fund their account belong to them or that the transaction is legitimate and authorized.

Additional verification may be required before certain withdrawals are processed.

15. Prohibited Activities

Customers must not use JujuVegas services for:

• Money laundering;
• Concealing the origin of criminal proceeds;
• Concealing the ownership or control of funds;
• Fraudulent financial transactions;
• Use of stolen or unauthorized payment instruments;
• Circumventing AML controls;
• Evading applicable financial restrictions;
• Any other unlawful financial activity.

JujuVegas may take appropriate action where prohibited activity is suspected.

16. Account Restrictions and Closure

JujuVegas may restrict, suspend, or terminate an account where:

• Customer identity cannot be satisfactorily verified;
• Required AML information is not provided;
• Information provided by the customer is materially false or misleading;
• Suspicious activity is identified;
• The customer presents an unacceptable AML risk;
• The account is being used for prohibited financial activity;
• Applicable law or regulatory requirements require such action.

Any remaining funds will be handled in accordance with applicable law and the Company's terms and procedures.

17. Record Keeping

JujuVegas will maintain appropriate AML records, including:

• Customer identification and verification information;
• Customer risk assessments;
• Transaction records;
• Enhanced due diligence documentation;
• Source-of-funds information;
• AML investigations;
• Suspicious activity reports where applicable;
• Sanctions-screening records;
• Account restriction and closure decisions;
• Relevant compliance correspondence.

Records will be retained for the period required under applicable law.

18. Data Protection and Confidentiality

JujuVegas will handle customer information in accordance with applicable privacy and data-protection requirements.

AML information will only be accessed, processed, disclosed, and retained for legitimate legal, regulatory, compliance, security, or business purposes.

Access to AML information will be restricted to authorized personnel.

19. Employee Responsibilities

JujuVegas employees and relevant contractors are expected to comply with this AML Policy and applicable internal procedures.

Employees must promptly escalate potential money laundering concerns to the designated compliance function.

Employees must not knowingly assist a customer or third party in circumventing AML controls.

20. AML Training

JujuVegas may provide AML training to employees and relevant contractors based on their responsibilities.

Training may include:

• Money laundering risks;
• Customer verification procedures;
• Suspicious transaction indicators;
• Transaction monitoring;
• Source-of-funds procedures;
• Sanctions screening;
• Escalation procedures;
• Record keeping;
• Confidentiality requirements.

Training will be reviewed periodically to ensure that it remains appropriate for the Company's business and risk profile.

21. AML Compliance Officer

JujuVegas will designate an appropriately qualified person or compliance function responsible for AML oversight.

The AML Compliance Officer may be responsible for:

• Implementing this AML Policy;
• Maintaining AML procedures;
• Conducting AML risk assessments;
• Reviewing suspicious activity;
• Overseeing customer due diligence;
• Monitoring AML controls;
• Maintaining AML records;
• Coordinating regulatory reporting;
• Managing AML training;
• Reviewing the effectiveness of AML procedures;
• Escalating material AML risks to senior management.

The exact responsibilities and authority of the AML Compliance Officer will be determined by applicable law and the Company's organizational structure.

22. AML Risk Assessment

JujuVegas will periodically assess its exposure to money laundering risks.

The assessment may consider:

• Customer risk;
• Geographic risk;
• Product and service risk;
• Payment-method risk;
• Transaction risk;
• Technology and delivery-channel risk;
• Third-party risk;
• Emerging money laundering risks.

The AML risk assessment will be updated when material changes occur to the Company's business, services, customer base, payment systems, jurisdictions, or regulatory obligations.

23. Internal Controls and Testing

JujuVegas may periodically test and review the effectiveness of its AML controls.

Reviews may include:

• Customer file reviews;
• Transaction-monitoring reviews;
• Sanctions-screening reviews;
• Suspicious activity case reviews;
• Account restriction reviews;
• Employee training assessments;
• Independent compliance assessments where appropriate.

Any material weaknesses identified should be documented and addressed within an appropriate timeframe.

24. Cooperation with Authorities

JujuVegas will cooperate with competent regulatory, law-enforcement, judicial, or financial-intelligence authorities where required by applicable law.

The Company may provide customer, transaction, account, and compliance information where legally required or permitted.

25. Confidentiality and Anti-Tipping-Off

Employees and representatives must maintain the confidentiality of AML investigations and related information.

Where applicable law prohibits disclosure, employees must not inform a customer or unauthorized third party that:

• A suspicious activity investigation is taking place;
• A suspicious transaction report has been submitted;
• Information has been provided to a competent authority;
• An AML-related regulatory action is being considered.

All external requests concerning AML investigations should be referred to the designated compliance function.

26. Customer Cooperation

Customers are required to provide accurate, complete, and current information when reasonably requested for AML purposes.

Failure to provide requested information may result in:

• Delayed transactions;
• Additional verification;
• Withdrawal restrictions;
• Account suspension;
• Account closure.

Any action taken will be subject to applicable law and JujuVegas procedures.

27. Policy Review

This AML Policy will be reviewed at least annually and whenever there is a material change to:

• Applicable AML laws or regulations;
• JujuVegas's business model;
• Products or services;
• Payment methods;
• Customer profile;
• Geographic markets;
• Money laundering risks;
• Regulatory requirements.

Changes to this Policy will be approved by the appropriate management or compliance authority.

28. Contact

For AML-related questions or compliance matters:

JujuVegas Compliance Department
Website: JujuVegas.com
Email: [support@jujuvegas.com]

Regulatory and law-enforcement requests should be directed to the official compliance contact designated by JujuVegas.

29. Declaration

JujuVegas is committed to maintaining effective measures designed to prevent its platform and services from being misused for money laundering or other unlawful financial activity.

This AML Policy forms part of JujuVegas's broader compliance framework and should be read together with the Company's Terms and Conditions, Privacy Policy, KYC procedures, Responsible Gambling Policy, and other applicable internal policies and procedures.