Anti-money Laundering

Purpose and Scope

Neon54 maintains this Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy to comply with applicable AML/CFT laws, regulations, and supervisory guidance. The Policy covers all Neon54 gaming operations, customers, employees, and representatives, and governs onboarding, funding, wagering, withdrawals, and any related financial activity conducted through Neon54 platforms and systems.

Legal Framework and Objectives

Neon54 implements a risk-based approach designed to detect and deter money laundering and the financing of terrorism. The objectives are to identify illicit activity, verify customer identity, monitor transactional patterns, and report suspicious activity to the competent authorities in accordance with applicable law. Neon54 undertakes to cooperate with law enforcement and supervisory bodies as required by law.

Customer Due Diligence (CDD) and Identity Verification

On onboarding and at regular intervals during the business relationship, Neon54 applies customer due diligence commensurate with the assessed risk profile. The following controls shall be implemented:

• Identity Verification: Obtain and verify the customer’s identity using reliable, independent sources. Required data includes full legal name, date of birth, residential address, and contact details. Verification may involve government-issued identification and corroborating documentation such as utility bills or official correspondence.
• Age Verification: Confirm that the customer meets the minimum age requirement for participation in online gaming as mandated by applicable law; Neon54 shall restrict access to players under the minimum age.
• Source of Funds and Wealth: Collect information on the customer’s source of funds and, where necessary, source of wealth to ensure the legitimacy of deposits. On deposits exceeding EUR 2,000, Neon54 will perform enhanced scrutiny of funds sources.
• Risk Classification: Assign a risk level (low, medium, high) based on factors such as geography, account activity, channel, product type, and transaction patterns. The risk classification determines the depth and cadence of ongoing due diligence.
• Record of Information: Maintain records of identity verification, risk assessment, and source of funds information for the duration of the account relationship and for a minimum period of seven years after closure or termination.

Enhanced Due Diligence (EDD)

Neon54 applies Enhanced Due Diligence for high-risk customers or transactions, including but not limited to: additional identity verification steps, obtaining independent verification of sources of funds, enhanced monitoring of account activity, and senior management approval for ongoing relationships.

Ongoing Monitoring and Screening

Neon54 maintains ongoing monitoring for all active accounts. The monitoring program includes:

• Transaction Monitoring: Automated and manual review of transactions against customer risk profiles; flag unusual, complex, or high-value activity for investigation.
• Sanctions and PEP Screening: Routine screening against applicable sanctions lists and politically exposed persons (PEP) indicators; escalate any hits for review and escalation in accordance with policy.
• Ongoing Data Review: Periodic updates to customer information and documentation in line with risk-based expectations.

Recordkeeping and Data Retention

Neon54 shall securely store all AML/CFT records, including due diligence materials, transaction records, internal reports, and correspondence, for a minimum of seven years from the date of the relevant event or account termination, whichever lasts longer, in a manner that protects confidentiality and data integrity.

Suspicious Activity Reporting and Cooperation

If Neon54 identifies or reasonably suspects suspicious activity, it shall escalate promptly to the Compliance Officer for internal review and, where warranted, file a report with the competent financial intelligence authority in accordance with applicable law. Neon54 shall cooperate with regulatory and law enforcement authorities and provide information and access as required by law and competent authorities, subject to applicable data protection obligations.

Roles, Responsibilities and Governance

Board and Senior Management bear ultimate responsibility for AML governance. A designated Compliance Officer oversees the implementation of this Policy, ensures staff training, and coordinates with regulators. All employees and contractors must comply with the AML/CFT procedures, report suspicious activity through established internal channels, and complete mandated AML/CFT training.

Training and Awareness

Neon54 provides ongoing AML/CFT training to all relevant staff. Training covers identification of suspicious activity, proper escalation procedures, customer due diligence, recordkeeping obligations, and regulatory changes.

Data Protection and Privacy

All personal data collected for AML/CFT purposes is processed in accordance with applicable data protection laws. Access to KYC and AML records is restricted to authorized personnel on a need-to-know basis, and data minimization, retention, and secure storage measures are maintained consistent with policy and legal requirements.

Policy Governance, Review and Amendments

This AML/CFT Policy is reviewed at least annually, and more frequently in response to regulatory changes or material business developments. Updates require approval by Neon54’s Board or designated supervisory authority as appropriate. Customers will be notified of material changes in accordance with applicable law and Neon54’s Terms and Conditions.

Prohibited Activities and Compliance Notes

Neon54 may suspend, restrict, or terminate an account that presents unmitigated AML/CFT risk or non-compliance with this Policy. Neon54 will not tolerate attempted circumvention of identity verification, fund provenance checks, or reporting obligations, and shall take appropriate action consistent with applicable law, including potential referral to authorities and account closure.

Contact, Escalation and Access to Information

Any questions about this Policy or reports of suspicious activity should be directed to Neon54’s Compliance Team through established secure channels. All inquiries and reports will be handled confidentially and in accordance with applicable privacy laws and internal procedures.