Anti-Money Laundering (AML) & Combating the Financing of Terrorism (CFT)-Compliance Policy
1. Regulatory Commitment
MOBILE INCORPORATED Limited (the “Company”) operates under a B2C Gaming Service Licence issued by the Malta Gaming Authority and is subject to Maltese Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) legislation.
As a subject person under Maltese law, the Company applies a risk-based framework designed to prevent, detect, and report money laundering, terrorist financing, fraud, and related financial crime.
This Policy applies to all customers using the Company’s gaming and betting services.
2. Customer Due Diligence (CDD)
2.1 Identification and Verification
Prior to or during the establishment of a business relationship, the Company performs identity verification measures, including:
- Collection of valid government-issued photo identification
- Verification of full legal name, date of birth, and residential address
- Confirmation that the customer is at least 18 years of age
Verification may be completed through reliable electronic verification systems or manual document review.
The Company reserves the right to suspend account functionality until satisfactory verification is completed.
2.2 Enhanced Due Diligence (EDD)
Enhanced measures are applied where:
- A customer is classified as high risk
- Politically Exposed Person (PEP) status is identified
- Transactions exceed predefined thresholds
- Source of funds is unclear
- Geographic risk factors are present
EDD may include additional documentation, independent source verification, and senior management approval.
3. Source of Funds & Wealth Assessment
The Company may request evidence supporting the legitimacy of funds deposited on the platform, including:
- Bank statements
- Payslips or employment confirmation
- Corporate documentation (where applicable)
- Asset sale agreements
Deposits and withdrawals may be temporarily restricted pending satisfactory clarification.
4. Transaction Monitoring
The Company maintains automated and manual monitoring systems designed to identify:
- Unusual deposit and withdrawal patterns
- Rapid in-and-out transactions
- Structuring or layering behaviour
- Betting activity inconsistent with customer profile
Alerts are reviewed by trained compliance personnel.
Where suspicion arises, the Company may:
- Conduct additional due diligence
- Restrict account access
- Submit a Suspicious Activity Report (SAR)
5. Sanctions & PEP Screening
Customers are screened against:
- EU consolidated sanctions lists
- UN sanctions lists
- National sanctions lists
- Politically Exposed Person databases
Screening is conducted at onboarding and periodically thereafter.
6. Reporting Obligations
Where knowledge or suspicion of money laundering or terrorist financing arises, the Company submits a Suspicious Activity Report to the Financial Intelligence Analysis Unit (FIAU) in accordance with Maltese law.
Tipping-off is strictly prohibited.
The Company fully cooperates with:
- Malta Gaming Authority
- FIAU
- Law enforcement authorities
7. Record Retention
In line with Maltese AML regulations:
- Customer identification data
- Transaction records
- Risk assessments
- SAR documentation
are retained for a minimum of five (5) years following the end of the business relationship.
8. Risk-Based Customer Assessment and Periodic Reporting
The Company applies a risk-based methodology to customer onboarding and ongoing monitoring. Users are classified based on risk factors including:
- Geographic location
- Transaction volume and patterns
- Account activity and behavioral indicators
High-risk users are subject to enhanced due diligence, including additional verification and more frequent monitoring. Periodic risk assessment reports are prepared and submitted to the MGA as required under licensing conditions, demonstrating the Company’s compliance with regulatory expectations.
9. User Obligations
All users are required to:
- Provide accurate and complete personal information during account registration
- Update their information promptly if any details change
- Provide documentation or information requested for AML/KYC verification
Failure to comply with AML/KYC requirements may result in account suspension, denial of transactions, or account closure, consistent with MGA licensing requirements.
10. Internal Governance & Training
The Company maintains:
- An appointed Money Laundering Reporting Officer (MLRO)
- Internal AML procedures and risk assessments
- Documented escalation protocols
- Periodic staff AML/CTF training
Compliance effectiveness is reviewed periodically.
11. Data Protection
All personal and financial information collected for AML/KYC purposes is handled in accordance with our Privacy Policy and applicable data protection standards, including GDPR, ISO/IEC 27701, and other applicable regulations. Data is stored securely and shared only with authorized parties for compliance purposes. Measures ensure the confidentiality, integrity, and appropriate retention of personal information, in line with MGA expectations.
KYC and AML records will be retained for at least five (5) years from the date a business relationship ends or the last transaction occurs, in line with MGA’s AML/CTF obligations.
12. Policy Amendments
This Policy may be revised to reflect legislative or regulatory updates. The latest version will be published on the Company’s website.
