Aml Policy

1. Introduction

Ibizabet maintains an anti money laundering and countering the financing of terrorism policy (AML policy) to prevent illicit financial activity on the platform and to comply with applicable legal and regulatory obligations. This policy governs all Ibizabet employees, contractors and any person acting on behalf of Ibizabet in relation to customer onboarding, account management and financial transactions.

2. Objectives and Legal Basis

The objectives of this policy are to: (a) deter, detect and report money laundering and terrorist financing; (b) ensure customer due diligence commensurate with risk; (c) protect the integrity of Ibizabet and its operating environment; and (d) cooperate with competent authorities as required by law. The policy is supported by applicable AML/CFT statutes, data protection rules and licensing conditions relevant to the jurisdictions in which Ibizabet operates.

3. Risk-Based Approach and Customer Risk Profiling

Ibizabet adopts a risk-based approach to AML that classifies customers and activities by risk. Risk categories include:

• Country risk, including residence in or frequent activity from high risk or sanctioned jurisdictions;
• Customer risk, including political exposure status and sanctions checks; and
• Transaction risk, including patterns of deposits, withdrawals and cross-border activity.

Risk indicators may include excessive depositing activity, use of multiple devices or IP addresses in a short period, and irregular geolocation data. The results of the risk assessment determine the level of due diligence required and ongoing monitoring intensity.

4. Customer Verification and CDD

Onboarding and any triggers identified by the risk assessment require Standard Verification (customer due diligence). Ibizabet will request, and the user must provide, the following where applicable:

• A government-issued identification document (e.g., passport or national ID);
• A clear photograph of the user holding the identification document, if requested by Ibizabet;
• A proof of residential address document (e.g., utility bill, bank statement) not older than 3 months unless local law prescribes otherwise;
• Payment instrument verification: a photograph of the payment card used or intended for deposits, with the cardholder name matching the account holder; CVV and the middle digits of the card number may be redacted, but the cardholder name must be visible;
• Where necessary, other documents or data to support identification and address verification; and
• In some cases, completion of a secure verification call or video session with Ibizabet support.

Verification is retained in accordance with data protection requirements and relevant record retention periods. Ibizabet may suspend or restrict access to features and funds until verification is complete or risk is mitigated.

5. Enhanced Verification for PEPs and High‑Risk Jurisdictions

Where a customer is a Politically Exposed Person or domiciled in a high‑risk jurisdiction, Ibizabet applies enhanced due diligence. The enhancements may include:

• Additional owner and source of wealth/source of funds information;
• Independent confirmation of identity and verification of beneficial ownership where applicable;
• Senior management approval for onboarding and ongoing business relationships;
• Additional document requests or data as required by local law and regulatory expectations; and
• In some cases, escalation to a designated officer for final approval.

Ibizabet reserves the right to refuse or temporarily suspend accounts pending satisfactory enhanced verification where risk cannot be mitigated.

6. Activity Monitoring

Ibizabet monitors all user activity for suspicious patterns. Suspicious activity includes, but is not limited to:

• Usage of multiple devices or multiple accounts from the same user;
• Geolocation inconsistencies or mismatches between declared residency, IP address, and device data;
• Unusual timing or frequency of deposits or payments; and
• Inconsistent or implausible withdrawal patterns relative to account history.

Any suspected activity is escalated to the anti‑fraud function for evaluation and appropriate action, which may include further verification, temporary restriction or account closure.

7. Transaction Monitoring and Payment Integrity

All transactions must be conducted through legitimate payment instruments registered to the user. Ibizabet applies the following controls:

• Third‑party deposits or withdrawals are not permitted; payments from anonymous or unverified instruments are prohibited;
• For card payments, the cardholder name must match the Ibizabet account holder; for electronic wallets, the registered email must match the account holder at signup;
• Where a deposit cannot be allocated to the original payment method, withdrawal shall be made to a method that allows verification of ownership or to the user’s bank account; and
• Ibizabet will not accept or withdraw funds to anonymous wallets or untraceable instruments; reconciliation will be performed to ensure funds are traceable to the user.

On completion of verification, transactions are assessed for consistency with the user’s profile and historical activity. Ibizabet may place hold or request additional documentation for large or unusual withdrawals.

8. Record‑Keeping and Data Protection

Ibizabet maintains comprehensive records of all verification documents, transaction data, and internal risk assessments for the period required by applicable law. Records include: customer identification data, supporting documents, transaction histories, escalation notes, and correspondence with regulators. Data handling complies with applicable data protection laws, including the right of access, correction and deletion where permitted by law.

9. Reporting and Cooperation with Authorities

Ibizabet has a designated Money Laundering Reporting Officer (MLRO) responsible for receiving disclosures from staff and for reporting suspicious activities to the competent authorities in accordance with law. Employees must report knowledge or reasonable suspicion of money laundering or terrorist financing. Disclosure to the subject of an investigation is prohibited (no tipping off). The MLRO will determine whether further action, including external reporting, is required and will preserve confidentiality throughout the process.

10. Governance, Roles and Responsibilities

Senior management bears responsibility for the implementation and ongoing effectiveness of this policy. The MLRO has independent authority, access to resources and the obligation to report to senior management and regulators as required. All staff are responsible for complying with verification, monitoring and reporting procedures and for timely escalation of any concerns.

11. Training and Awareness

Ibizabet provides ongoing AML training to relevant personnel, covering customer due diligence, enhanced due diligence for high‑risk customers, ongoing monitoring, escalation procedures, and reporting obligations. Training records are maintained to demonstrate compliance and effectiveness.

12. High‑Risk Jurisdictions and Sanctions

Ibizabet applies enhanced controls or may restrict access to customers located in or transacting from FATF designated high‑risk jurisdictions or sanctioned territories. Accounts associated with such jurisdictions undergo additional due diligence, ongoing monitoring, and may be declined or closed where required by law or risk appetite. Compliance with sanctions and AML regimes is mandatory, and information obtained for sanctions screening may be shared with authorities as permitted by law.

13. Amendments and Review

This AML policy may be amended or updated by Ibizabet at any time. Users will be notified of material changes following regulatory and licensing requirements. Continued use of the service after notification constitutes acceptance of the updated policy.