KYC & AML Policy

HADIABLA.COM

Operated under: Mistletoe Ltd (Registration number: 16083; Address: Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros)

Contact: destek@hadiabla.com

Last Updated: 01 June 2026

1. PURPOSE

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy establishes mandatory procedures to:

• Verify the identity of all players;
• Prevent fraud, money laundering, and terrorist financing;
• Ensure compliance with Anjouan regulations and FATF standards;
• Maintain a secure, transparent, and lawful gaming environment.

2. OBJECTIVES

The objectives of this Policy are to:

• Ensure compliance with applicable AML/CTF legislation and regulatory guidance;
• Prevent underage gambling and financial crime;
• Mitigate risks linked to high-risk jurisdictions and PEPs;
• Protect player funds and platform integrity;
• Promote transparency and responsible gaming.

3. SCOPE

This Policy applies to:

• All registered players of www.hadiabla.com;
• All financial transactions;
• Third-party service providers and partners;
• High-risk or unusual activities.

4. KEY KYC PRINCIPLES

HADIABLA.COM applies the following principles:

• Customer Identification – Mandatory identity verification;
• Risk-Based Approach – Due diligence based on risk profile;
• Continuous Monitoring – Ongoing account and transaction review;
• Record Retention – Minimum five (5) years;
• Regulatory Cooperation – Full transparency with authorities.

5. DUE DILIGENCE FRAMEWORK

HADIABLA.COM applies three levels of due diligence:

5.1 Simplified Due Diligence (SDD)

Applied to:

• Very low-risk users;
• Low transaction volumes;
• No risk indicators.

5.2 Customer Due Diligence (CDD)

Applied to:

• Standard users;
• Most registrations and transactions.

5.3 Enhanced Due Diligence (EDD)

Applied to:

• PEPs;
• High-risk jurisdictions;
• Transactions exceeding EUR/USD 10,000;
• Unusual behavior patterns.

EDD includes:

• Source of funds verification;
• Source of wealth analysis;
• Senior management approval;
• Increased monitoring.

6. CUSTOMER IDENTIFICATION & INFORMATION COLLECTION

During registration and verification, the following data is collected:

• Full legal name;
• Date of birth;
• Nationality;
• Residential address;
• Email and phone number;
• Payment method details.

7. DOCUMENT VERIFICATION REQUIREMENTS

7.1 Proof of Identity

Accepted documents:

• Passport;
• National ID card;
• Driver's license.

Requirements:

• Photo visible;
• Signature present (if applicable);
• Not expiring within 3 months;
• Holder is 18+;
• Matches account name.

7.2 Proof of Address

Accepted documents:

• Utility bill;
• Bank statement;
• Government correspondence.

Requirements:

• Issued within last 3 months;
• Full name matches ID;
• Residential address visible.

7.3 Selfie Verification

Players must submit:

• A live selfie holding the ID document;
• Clear visibility of face and document;
• Matching ID number and photo.

7.4 Payment Verification

May include:

• Bank statements;
• E-wallet screenshots;
• Card ownership confirmation.

8. VERIFICATION TRIGGERS

Full KYC is mandatory when:

• Lifetime deposits exceed EUR/USD 10,000;
• Any withdrawal is requested;
• Suspicious activity is detected;
• Risk indicators arise.

9. RESTRICTED JURISDICTIONS

Accounts are not accepted from:

• Austria
• France and territories
• Germany
• Netherlands and territories
• Spain
• Union of Comoros
• United Kingdom
• USA and territories
• FATF Blacklisted countries
• Any jurisdiction prohibited by Anjouan

This list is updated regularly.

10. POLITICALLY EXPOSED PERSONS (PEPs)

10.1 Identification

PEPs include persons holding prominent public functions and close associates.

10.2 Measures

For PEPs:

• Database screening;
• Senior management approval;
• Continuous monitoring;
• Mandatory EDD.

11. TRANSACTION & BEHAVIORAL MONITORING

11.1 Transaction Monitoring

Automated and manual systems detect:

• Large deposits/withdrawals;
• Structuring;
• Rapid fund movement;
• Linked accounts.

11.2 Behavioral Monitoring

We monitor:

• Problem gambling patterns;
• Fraud indicators;
• Manipulation attempts.

11.3 Trigger Events

Reviews are initiated upon:

• Profile changes;
• Inactivity followed by large activity;
• External alerts.

12. RECORD KEEPING & DATA PROTECTION

12.1 Retention

All records are stored for at least five (5) years after account closure.

12.2 Data Protection

Personal data is:

• Stored securely;
• Used only for compliance;
• Processed in line with GDPR principles.

12.3 Accessibility

Records are available to regulators upon request.

13. REPORTING OBLIGATIONS

13.1 Suspicious Activity Reports (SARs)

• Filed within 7 days of detection;
• Include detailed transaction analysis.

13.2 Threshold Reporting

• Transactions above EUR/USD 10,000 are reported where required.

14. ACCOUNT RESTRICTIONS & CONTROLS

HADIABLA.COM may:

• Suspend accounts;
• Freeze balances;
• Reject withdrawals;
• Terminate relationships;

if KYC is incomplete, false, or non-compliant.

15. FAILED KYC PROCEDURES

If verification fails:

• Reason is documented;
• Support ticket is created;
• Player is notified;
• Funds may be restricted.

Accounts are approved only after full compliance.

16. COMPLIANCE OVERSIGHT

16.1 Compliance Officer

A designated officer is responsible for:

• Policy implementation;
• Regulatory liaison;
• SAR reporting.

16.2 Internal Audits

Periodic reviews ensure effectiveness.

16.3 Staff Training

Employees receive ongoing AML/KYC training.

17. PENALTIES FOR NON-COMPLIANCE

Failure to comply may result in:

• Fines;
• License suspension/revocation;
• Criminal referral.

18. CONTINUOUS IMPROVEMENT

HADIABLA.COM commits to:

• Regular policy updates;
• Adoption of advanced verification technologies;
• Alignment with evolving regulations.

19. CONTACT INFORMATION

For compliance matters:

destek@hadiabla.com

20. GOVERNING LAW

This Policy is governed by the laws of the Union of Comoros and applicable Anjouan regulations.