Effective Date: June 1, 2025
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros
This Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy sets out the principles and procedures followed by IOGr B.V. (“Company”, “we”, “our”, or “us”) in relation to the operation of chickenroad-game-official.ca, including all related domains, systems, and services (collectively, the “Website”).
The purpose of this Policy is to ensure compliance with applicable laws and regulatory standards and to prevent the misuse of our services for money laundering, terrorist financing, fraud, or other unlawful activities.
1. Purpose and Scope
This Policy applies to all business-to-business (B2B) relationships established by the Company. This includes, without limitation:
- Licensed gaming operators
- White-label and platform partners
- Distributors, resellers, and aggregators
- Technology providers and system integrators
- Other corporate counterparties
The Company does not provide services directly to individual end users, and this Policy does not apply to consumer-level players.
2. Risk-Based Compliance Methodology
The Company follows a risk-based approach when assessing and monitoring client relationships. Each prospective and existing client is evaluated to identify potential financial crime risks before onboarding and throughout the duration of the business relationship.
Risk assessments may consider factors such as:
- Country of incorporation and primary operating jurisdictions
- Ownership and governance structure, including Ultimate Beneficial Owners (“UBOs”)
- Business activities, product offerings, and target markets
- Regulatory licensing status and compliance history
- Reputational risk and adverse public information
- Transactional behavior, where applicable
Based on the outcome, clients are categorized as either standard risk or higher risk, which determines the level of due diligence required.
Risk classifications are reviewed at least annually and following any material change.
3. Standard Due Diligence (CDD)
Prior to establishing a business relationship, all clients must complete Customer Due Diligence.
As part of this process, clients may be required to submit the following documentation:
- Certificate of Incorporation or equivalent registration record
- Extract from a recognized commercial or trade register
- Articles and/or Memorandum of Association
- Proof of registered business address
- Organizational and ownership structure diagram
- Identification details of directors and shareholders
For each Ultimate Beneficial Owner holding 25% or more ownership or control, the following is required:
- Valid government-issued photo identification
- Proof of residential address
Documents should generally be recent and accurate, typically issued within the last three (3) months where applicable.
4. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied where a client presents increased risk.
Situations that may trigger EDD include, but are not limited to:
- Connections to jurisdictions identified as high-risk or non-cooperative by the FATF
- Complex or opaque ownership or control structures
- Involvement of Politically Exposed Persons (PEPs), their close associates, or family members
- Previous regulatory enforcement actions, sanctions exposure, or significant adverse media
EDD measures may include additional steps such as:
- Verification of Source of Funds (SoF) and Source of Wealth (SoW)
- Confirmation of valid gaming or operational licenses
- Independent compliance reports or AML audit findings
- Expanded sanctions, reputational, and background screening
The Company reserves the right to decline onboarding or terminate relationships where identified risks cannot be sufficiently mitigated.
5. Ongoing Monitoring and Reviews
All active client relationships are subject to continuous monitoring to ensure ongoing compliance with KYC and AML requirements.
Monitoring measures include:
- Periodic review of KYC documentation
- Event-driven reviews triggered by changes in ownership, management, jurisdiction, or licensing
- Review of unusual or inconsistent activity
Clients are required to notify the Company promptly of any changes that may affect their risk profile.
6. Sanctions and PEP Screening
The Company screens directors, shareholders, and UBOs against applicable international sanctions and PEP databases, including those maintained by the United Nations, European Union, and OFAC, as well as recognized third-party data providers.
Confirmed matches or material adverse findings may result in enhanced due diligence, suspension of services, refusal of onboarding, or reporting to competent authorities where legally required.
7. Record Retention
KYC and AML records are retained securely in electronic or physical form for a minimum period of six (6) years following the end of the business relationship, in accordance with applicable regulatory obligations.
8. Restricted Jurisdictions
The Company does not enter into or maintain business relationships with entities that are:
- Registered in or controlled from FATF high-risk or non-cooperative jurisdictions
- Subject to United Nations, European Union, or OFAC sanctions
- Operating within the Union of the Comoros for white-label services targeting that jurisdiction
- Otherwise restricted by the Anjouan Offshore Financial Authority
9. Non-Compliance and Enforcement
Failure to provide accurate, complete, or timely KYC/AML information may result in:
- Refusal to onboard
- Temporary or permanent suspension of services
- Termination of contractual agreements
- Reporting to regulatory or law enforcement authorities where required by law
10. Policy Amendments
This Policy may be updated periodically to reflect changes in laws, regulations, or internal compliance practices. The most current version will always be available on the Website and becomes effective upon publication unless stated otherwise.
Where practicable, material updates will be communicated to affected clients in advance.