AML POLICY

This Anti-Money Laundering and Counter-Terrorist Financing Policy ("AML Policy") applies to WINDICE GROUP LIMITED, registration number 2157509, registered at Intershore Chambers, Road Town, Tortola, British Virgin Islands, operating the website windice.io ("Windice", "we", "us", or "our").

Windice is committed to preventing money laundering, terrorist financing, sanctions evasion, fraud, corruption, and any other unlawful or abusive use of its services. This AML Policy explains the controls Windice may apply to protect its platform, users, business partners, and applicable regulatory obligations.

By opening or using an account on Windice, you acknowledge that you have read, understood, and agreed to comply with this AML Policy, our Terms of Service, and our Privacy Policy.

1. Purpose of this Policy

The purpose of this AML Policy is to:

prevent Windice from being used for money laundering, terrorist financing, sanctions evasion, fraud, theft, or any other unlawful activity;
maintain a risk-based compliance framework for customer due diligence, transaction review, and suspicious activity handling;
explain the circumstances in which Windice may request identity or source-of-funds information, delay or refuse transactions, suspend accounts, or report matters to competent authorities; and
set out additional rules that apply where Windice makes third-party fiat-to-crypto on-ramp or off-ramp services available.

2. Prohibited Use

You must not use Windice:

in violation of any applicable law, regulation, sanction, or regulatory requirement;
from any prohibited, restricted, or otherwise ineligible jurisdiction;
if you are under the legal age required to use the services in your jurisdiction;
on behalf of another person or entity, unless expressly approved by Windice in writing;
to conceal, transfer, layer, structure, or clean the proceeds of crime;
as a money transmission service, mixing service, tumbling service, bridge for anonymous value transfer, or pass-through wallet;
using stolen funds, stolen credentials, unauthorized payment instruments, or assets connected to fraud, theft, ransomware, darknet activity, sanctions exposure, or any other illicit source;
using false, forged, altered, misleading, or incomplete information or documents; or
in any way intended to circumvent Windice's security, geolocation, verification, payment, wagering, sanctions, or compliance controls.

3. Risk-Based Compliance Approach

Windice applies a risk-based approach. This means that the level of review, monitoring, and verification may vary depending on the risk presented by the user, transaction, wallet address, payment method, jurisdiction, device, behavior, and other relevant factors.

Windice may apply simplified checks in lower-risk situations and enhanced checks in higher-risk situations. Windice may also change the level of scrutiny at any time based on updated information, user activity, partner alerts, law enforcement inquiries, or internal risk signals.

4. Customer Due Diligence and KYC

Windice reserves the right, at any time, to perform Know Your Customer ("KYC") and other due diligence checks in order to verify a user's identity, age, location, ownership of funds, and lawful use of the platform.

Windice may request one or more of the following:

full legal name;
date of birth;
residential address;
nationality and country of residence;
government-issued photo identification;
proof of address;
selfie, liveness check, or facial comparison;
proof of ownership of a payment method, wallet, or source address;
source of funds and/or source of wealth evidence;
bank, exchange, or wallet statements;
transaction history;
employment, business, or occupation information; and
any other information or documents reasonably necessary to complete a compliance review.

Windice may use internal systems and/or third-party service providers to help verify identity, geolocation, transaction risk, sanctions exposure, wallet risk, device risk, fraud indicators, and related compliance factors.

Failure to provide requested information in a timely manner may result in restrictions on your account, deposits, gameplay, bonuses, withdrawals, or account closure.

5. Enhanced Due Diligence

Windice may apply Enhanced Due Diligence ("EDD") where higher risk is identified. EDD may include additional document requests, deeper transaction review, manual compliance analysis, senior review, or a temporary hold on withdrawals or account access.

EDD may be triggered by factors including, without limitation:

large, unusual, rapid, or high-value transactions;
activity inconsistent with your known profile, location, payment history, or prior behavior;
deposits and withdrawals with little or no genuine gaming activity;
attempted use of Windice as a mixer, intermediary, transfer tool, or cash-out channel;
exposure to sanctioned persons, sanctioned jurisdictions, blacklisted services, or high-risk counterparties;
wallet activity associated with mixers, tumblers, darknet services, scams, fraud, ransomware, hacked funds, or other illicit typologies;
use of VPNs, proxies, remote desktops, spoofing tools, or other evasion methods;
discrepancies in identity, address, source-of-funds, device, or ownership information;
multiple accounts, account sharing, or third-party operation;
links to politically exposed persons ("PEPs"), close associates, or higher-risk public functions;
chargeback, fraud, or abuse alerts from payment processors or on-ramp providers; or
requests, notices, or inquiries from regulators, financial intelligence units, law enforcement, courts, or other competent authorities.

6. Source of Funds and Source of Wealth

Where required by Windice, you must be able to demonstrate that the funds or cryptoassets used on the platform come from a lawful and legitimate source.

Windice may require evidence relating to your source of funds and/or source of wealth, including but not limited to:

salary or employment records;
business income records;
sale of assets;
exchange or trading account statements;
bank statements;
tax documentation;
inheritance documentation;
investment records; or
blockchain history demonstrating lawful ownership and transfer path.

Windice may refuse to accept or process funds where the lawful origin of funds cannot be satisfactorily established.

7. Sanctions, PEP, and Adverse Media Screening

Windice may screen users, counterparties, wallet addresses, source addresses, destination addresses, and related data against:

international sanctions lists;
watchlists and enforcement databases;
politically exposed person ("PEP") databases;
adverse media sources; and
internal and third-party risk intelligence tools.

If Windice identifies a match, partial match, or risk indicator requiring review, Windice may request further information, restrict activity, suspend the account, refuse a transaction, or take any other action considered appropriate under applicable law or internal controls.

8. Blockchain and Transaction Monitoring

All deposits, withdrawals, and related account activity may be reviewed for compliance purposes.

Windice may monitor:

transaction size, frequency, and velocity;
wagering behavior and turnover patterns;
deposit-to-withdrawal ratios;
wallet clustering and destination risk;
blockchain exposure to high-risk services;
unusual transfer paths or layering patterns;
device, IP, geolocation, and login anomalies; and
any other data points relevant to fraud prevention, AML/CFT, sanctions compliance, or platform abuse detection.

Windice may use blockchain analytics tools, fraud systems, and manual review to identify suspicious or high-risk activity.

9. Anti-Mixing and Non-Genuine Use of the Platform

Windice is a gaming platform and must not be used as a crypto mixer, intermediary, or transfer channel.

Where Windice suspects that a user is attempting to use the platform primarily to move, obfuscate, recycle, or cash out funds rather than for genuine gaming activity, Windice may take one or more of the following actions:

require a minimum wagering turnover before a withdrawal is processed;
refuse or delay a withdrawal;
return funds, where reasonably possible, to the originating source;
void bonuses or promotional benefits connected to abusive behavior;
suspend or close the account; and/or
escalate the matter for compliance review or reporting.

Nothing in this section limits any broader rights Windice may have under its Terms of Service or applicable law.

10. Third-Party On-Ramp and Off-Ramp Providers

Where Windice makes a third-party fiat-to-crypto on-ramp or off-ramp available in the cashier or elsewhere on the website, that service is provided by an independent third-party provider and may be subject to separate terms, privacy notices, verification procedures, risk scoring, transaction limits, regional availability rules, and compliance decisions.

In such cases:

the on-ramp/off-ramp provider may conduct its own KYC, AML, fraud, sanctions, chargeback, and transaction-risk checks;
Windice may require that the person using the on-ramp/off-ramp is the same person who owns and uses the Windice account;
Windice may decline to credit, release, or process transactions where ownership, identity, or lawful source cannot be confirmed;
Windice may receive limited information from the provider necessary to confirm transaction status, compliance outcome, fraud concerns, or account matching;
the provider may refuse, reverse, cancel, or delay a transaction under its own compliance rules; and
availability of a third-party provider in the Windice interface does not guarantee that any purchase, sale, deposit, or payout will be accepted.

You are responsible for complying with the provider's requirements in addition to Windice's requirements.

11. Wallet Ownership and Payment Method Rules

You may only use wallets, payment methods, bank accounts, cards, exchange accounts, or on-ramp/off-ramp accounts that you lawfully own or are expressly authorized to use.

Windice may require proof that:

a deposit address, source wallet, or source exchange account belongs to you;
a withdrawal address is controlled by you;
the name on any payment instrument or on-ramp/off-ramp account matches the verified account holder; and
no third party is funding, operating, or receiving value from your Windice account without approval.

Windice may reject transactions involving third-party ownership, nominee arrangements, mule behavior, or unexplained wallet substitution.

12. Ongoing Monitoring and Periodic Re-Verification

Verification is not a one-time event. Windice may carry out ongoing monitoring and may request updated or additional information at any time, including after previous verification was completed.

Windice may re-verify an account due to:

changes to account details;
changes in jurisdiction or device patterns;
increased volume or risk;
suspicious or unusual activity;
payment or blockchain alerts; or
legal, regulatory, or partner requirements.

13. Actions Windice May Take

To protect the platform and comply with legal obligations, Windice may, at its sole discretion and without prior notice where appropriate:

request documents, explanations, or declarations;
place deposits, withdrawals, bonuses, or gameplay under review;
delay or refuse any deposit, bet, transfer, bonus, or withdrawal;
block, reverse, cancel, or return a transaction where possible;
restrict account functionality;
freeze or withhold funds pending review;
suspend or permanently close an account;
void promotions or bonus balances linked to abusive or unlawful conduct;
refuse service to a user, address, transaction, region, or counterparty; and/or
report information or cooperate with competent authorities, regulators, financial intelligence units, or law enforcement.

Windice is not required to disclose the specific internal triggers, monitoring rules, risk models, or investigative methods used in a compliance review.

14. Reporting and Cooperation with Authorities

Where required or considered appropriate under applicable law or legitimate compliance obligations, Windice may report suspicious, unusual, criminal, sanction-related, or otherwise prohibited activity to competent authorities or cooperate with lawful requests for information, freezing measures, investigations, or enforcement actions.

Windice may be prohibited from notifying a user about certain reports, alerts, investigations, or government requests.

15. Record Retention

Windice may retain KYC records, transaction data, communications, device data, risk assessments, blockchain review results, and other compliance-related materials for as long as required by applicable law, regulatory expectations, legitimate business needs, audit requirements, dispute resolution needs, or enforcement interests.

16. No Right to Immediate Withdrawal During Review

Nothing in this AML Policy obliges Windice to process a withdrawal, release funds, or complete verification while a compliance, fraud, sanctions, source-of-funds, or security review is ongoing.

Where a review is underway, processing times may be extended until Windice is satisfied that the activity is lawful, genuine, and compliant.

17. Policy Changes

Windice may amend this AML Policy at any time in order to reflect legal, regulatory, operational, technological, or business changes. The latest version published on windice.io will apply from its stated effective date.

You are responsible for reviewing the current version of this AML Policy before using the services.

18. Contact

Email: [email protected]

By using Windice, you confirm that you will cooperate fully with any compliance review and that your use of the platform will remain lawful, genuine, and consistent with this AML Policy.