Anti-Money-Laundering (AML) Policy

Adriana Sweeps is committed to preventing its services from being used for money laundering (“ML”) or terrorist financing (“TF”). This policy applies to all customers, employees, and partners and supports our obligations under applicable AML/CTF laws and our gaming license conditions.

We apply a risk-based approach, assessing each customer and transaction for ML/TF risk based on factors such as deposit/withdrawal size and velocity, geography, payment method, and behavior. Higher-risk situations trigger enhanced due diligence.

Before allowing certain activity (including withdrawals), we verify customer identity, age, and location as described in our KYC Policy. We may apply Enhanced Due Diligence (EDD) — requesting source-of-funds or source-of-wealth evidence — for higher-risk customers, large transactions, or politically exposed persons (PEPs).

We monitor activity for suspicious patterns. Our systems automatically flag transactions for manual review based on heuristics such as:

• Withdrawals above a configured monetary threshold.
• Unusual deposit-then-immediate-withdrawal patterns with little or no play.
• Rapid repeated deposits or withdrawals (velocity).
• Mismatches between account, payment, and verification details.

Flagged transactions may be held, delayed, or declined pending review, and we may request additional documentation.

Deposits are credited only after a payment is verified. We may require that withdrawals are returned to the same verified payment method used to deposit. We may refuse activity where the source of funds cannot be satisfactorily established.

We retain customer-identification records, transaction histories, and AML decisions for the period required by law (typically at least five years after the relationship ends), and maintain audit logs of relevant actions.

Where we have reasonable grounds to suspect ML/TF, we will file the required reports (e.g. Suspicious Activity Reports) with the competent authorities and may be legally prohibited from “tipping off” the customer. We cooperate fully with law enforcement and regulators.

We screen against applicable sanctions lists and prohibit use by persons or in territories subject to sanctions or where our services are not licensed. Accounts found in breach may be frozen or closed.

We maintain an AML program with a designated compliance officer, staff training, independent review, and regular updates. [Operator: insert the name/role of the Money Laundering Reporting Officer, applicable statutes, and reporting authority as confirmed by counsel.]