Anti-money Laundering

Anti‑Money Laundering and Know Your Customer (KYC) Compliance

8www implements a risk‑based AML program designed to prevent money laundering and the financing of terrorism in accordance with applicable laws and licensing requirements. This policy sets out the controls for customer identification, ongoing monitoring, and the escalation of suspicious activity, as well as the rights and responsibilities of customers and the operator.

Scope and Applicability

This policy applies to all customers, their transactions, and any business relationships conducted through 8www. It governs onboarding, identity verification, ongoing monitoring of activity, withdrawals, and any sanctions, PEP, or risk assessments performed by the operator.

Customer Identification Program (CIP) and Verification Framework

• 8www applies a risk‑based approach to customer onboarding that includes identity verification, address verification, and assessment of source of funds for deposits and anticipated activity.
• Verification is required prior to enabling certain withdrawal capabilities and for high‑risk transactions or jurisdictions, and may be conducted at ongoing intervals throughout the customer relationship.
• Documentation collected and retained shall be sufficient to establish the customer’s identity and the legitimacy of funds, and will be treated in accordance with data protection obligations.

Identity Verification

• The customer must provide a clear copy of a government‑issued photo ID. Acceptable documents include a passport, national identity card, or driver’s license, and the copy must show the full document and be legible.
• If the customer does not possess a valid photo ID, alternative verification is allowed in accordance with applicable laws, which may include a birth certificate and additional corroborating information. When applicable, the customer may be required to provide a self‑tied image with the identification document for verification purposes.

Proof of Address

• The customer shall provide a proof of address document issued within the last three months. Acceptable documents include a utility bill or a bank or financial institution statement showing the customer’s name and residential address.

Proof of Payment (Source of Funds and Deposit Verification)

• 8www requires verification of the source of funds corresponding to deposits. The specific documentation depends on the payment method used.
• Card payments: provide copies of the debit or credit card used, displaying the customer’s signature, and the first six and last four digits of the card. The middle digits and security code must be obscured.
• e‑wallets: provide a screenshot or screenshot‑style image showing the customer’s account email or identifier and associated account details with the customer’s name visible.
• Bank transfers: provide a bank statement or a PDF copy that shows the customer’s name, account number, IBAN, BIC/SWIFT, and the relevant deposit details matching 8www records.
• Cryptocurrencies: provide a transaction receipt and a wallet profile screenshot that shows the customer’s email and account information.
• Prepaid vouchers: documentation for prepaid methods is not considered verification of funds in itself and may require alternative verification per risk assessment.

Documentation Submission Process

• Documents must be uploaded by the customer through the designated area within the account profile. 8www shall provide secure channels for the upload of documents and the display of verification status.
• Where a withdrawal request is pending, documentation may be requested and must be supplied within 48 hours of the withdrawal request. The operator shall review submitted documents within 3 business days and determine the outcome.

Ongoing Monitoring and Risk Management

• All customer activity is subject to ongoing monitoring for suspicious or unusual behavior. 8www applies risk scoring to customers and transactions, and escalates high‑risk cases to enhanced due diligence or freeze/closure as appropriate.
• Transactions and accounts may be temporarily restricted if findings indicate potential AML/CTF concerns or if regulatory requirements demand heightened scrutiny.

Withdrawals, Payouts, and Source of Funds Checks

• Withdrawals are only payable to payment methods previously used by the customer for deposits, and withdrawal requests are subject to verification and funds availability checks.
• The amount available for withdrawal per payment method is shown to the customer on the withdrawal screen. Processing times may vary by method but shall be notified in advance where practicable; typical processing may extend to a reasonable period not exceeding 72 hours unless a longer period is mandated by applicable law or a security review.
• 8www may suspend or delay a withdrawal if verification is incomplete, if there is a reason to suspect fraudulent activity, or if required by law or regulation. In such cases, the customer will be informed of the basis for the action and the steps required to resolve it.

Record Keeping, Data Protection, and Confidentiality

All information collected under this policy shall be retained in accordance with applicable legal and regulatory retention periods and 8www’s Privacy Policy. Records shall be stored securely, access shall be restricted to authorized personnel, and data shall be processed in compliance with data protection law. Information may be disclosed to competent authorities where permitted by law and when necessary to meet AML/CTF obligations.

Suspicious Activity Reporting and Compliance Cooperation

• 8www shall report suspicious activities and transactions to the relevant authorities in accordance with applicable legal and regulatory requirements. The operator maintains internal audit trails and may preserve evidence in accordance with law.
• 8www cooperates with law enforcement, auditors, and regulators as required, and does not disclose information about ongoing investigations except as permitted by law.

Sanctions, Political Exposure, and Risk Mitigation

• 8www conducts sanctions screening and political exposure risk assessments. A finding of risk may trigger enhanced due diligence, transaction restrictions, account monitoring, or account termination consistent with legal obligations and internal policy.

Training, Compliance Program, and Audits

8www maintains a formal AML training program for staff and conducts regular internal and external reviews to verify compliance with this policy and applicable law. Audits assess effectiveness of customer due diligence, monitoring, and reporting controls.

Customer Rights and Dispute Resolution

• Customers have the right to be informed of verification requirements, to submit documentation, and to receive explanations of decisions related to account verification, limitations, or restrictions where lawful and permissible.
• Disputes regarding AML determinations may be addressed through the operator’s dispute resolution framework in accordance with applicable consumer protection rules and licensing requirements.

Definitions and Key Terms

• Anti‑Money Laundering (AML): procedures to detect and prevent money laundering and the financing of terrorism.
• Know Your Customer (KYC): processes to verify customer identity and assess risk.
• Customer Identification Program (CIP): the set of controls used to verify the identity of customers.
• PEP: politically exposed person; enhanced due diligence may be applied where applicable.
• Source of Funds: the origin of the funds used in deposits and activity, to be verified according to risk and method.

Policy Governance and Revisions

This AML and KYC policy is reviewed at least annually and updated as required to reflect changes in law, licensing obligations, or risk assessment results. The latest version governs all customer relationships and transactions conducted on 8www.