AML Policy & Standard KYC Procedures

As a responsible betting company, Top90 fully complies with all applicable industry standards. We are committed to establishing long-term relationships with our customers and take pride in our ability to provide personalized services tailored to each customer's needs and goals. In addition to our excellent customer relations, we strictly adhere to anti-money laundering (AML) regulations to protect our customers’ assets and deliver top-tier financial services.

To maintain this balance between compliance and service quality, Top90 requires customers to provide high-resolution identification and proof of address (no older than three months) for any withdrawal request.

Standard KYC Requirements:

For all customers making their first withdrawal request:

• A copy of a passport or national ID;
• A utility bill issued within the last 3 months (as proof of address).

Top90 may request justification for specific financial transactions. In such cases, relevant contracts, invoices, or purchase orders will be requested. Top90 reserves the right to contact associated parties to verify the legitimacy of transactions. Additionally, all account details are communicated to account holders via email, and the registered phone number may be contacted when necessary. Any changes in contact information must be reported.

AML Policy

2.1. Policy and Definition

Top90 has a strict zero-tolerance policy against money laundering. Any attempt to disguise the origin of funds obtained through illegal means is considered money laundering.

All Top90 affiliates are required to comply with this AML policy and applicable anti-money laundering legislation. Failure to do so may result in severe criminal penalties and fines.

Top90 actively prevents chip dumping, collusive betting, and any suspicious activity. Such practices are strictly prohibited and violate the core principles Top90 has upheld since its founding.

Top90 applies a series of filtering processes to monitor financial transactions and ensure they are free from money laundering risk.

Customer Commitments:

• Customers agree to comply with all laws related to proceeds from criminal activity and money laundering during their time as Top90 users.
• Customers agree to fully cooperate with Top90 in anti-money laundering efforts.
• Top90 reserves the right to suspend or terminate accounts suspected of being used for illegal activities and may block or delay any transaction that may violate applicable laws.

Top90 also reserves the right to use customer data to investigate suspected fraud or other illegal activity.

2.2. Risk Assessment

Top90 uses a standardized risk rating model to evaluate potential money laundering risks in all customer relationships. This model is reviewed and approved annually by the Top90 Board of Directors.

2.3. Suspicious Activities

Examples of activity that may be considered suspicious by Top90 include:

• Customers who show unusual concern or resistance regarding AML procedures.
• Customers with a known history of legal or criminal violations.
• Customers acting on behalf of unidentified third parties.
• Customers frequently making large deposits and requesting cash-only transactions.
• Customers engaging in a high volume of transactions using multiple accounts or involving third-party accounts.
• Customers who are nationals of, or maintain accounts in, countries listed as Non-Cooperative Jurisdictions by the Financial Action Task Force (FATF).
• Dormant accounts that suddenly begin receiving large transfers.

Top90 takes appropriate measures to monitor all account activity and customer transactions.

2.4. Customer Identification Procedures

Top90 employs various procedures to verify the true identity of its customers. Accounts for which identification cannot be verified within an acceptable timeframe will be suspended or, if necessary, terminated.

Identification requirements for individuals include:

• Full legal name and any other names used (e.g., maiden name)
• Residential address
• Phone number
• Email address
• Date and place of birth
• Country of residence
• An official government-issued photo ID (e.g., ID card, passport, or driver’s license)

2.5. Record Keeping

Top90 retains all document and service records for the minimum period required by applicable law.

2.6. Training

Top90 has a comprehensive training policy that includes mandatory AML training for all new employees. Staff are also required to participate in annual refresher training programs.

2.7. Governance

Top90 appoints a dedicated AML Compliance Officer responsible for managing the company’s anti-money laundering policies. This officer is accountable for interpreting, updating, and ensuring the enforcement of AML procedures within Top90.