Introduction
Xhjili is committed to preventing money laundering and the financing of terrorism. This AML & KYC Policy sets out how we verify customers, monitor activity, and protect the integrity of our platform.
Legal Basis, Scope and Application
The policy implements applicable AML/CFT laws and regulatory requirements in jurisdictions where Xhjili operates. It applies to all customers and all activities on the Xhjili platform, including onboarding, deposits, withdrawals, and gaming or wagering activities.
Identity Verification and KYC
- Account opening obligations: Before permitting high-risk transactions, Xhjili will verify identity and residence details.
- Required documents: Government-issued photo ID (passport, national ID) and proof of address (utility bill or bank statement not older than 3 months).
- Verification methods: Document verification combined with biometric verification where available; liveness checks may be required.
- Source of funds and wealth: For deposits exceeding EUR 2,000 within any rolling 30-day window, customers must provide documentation evidencing source of funds and, where applicable, source of wealth.
- Account restrictions during verification: If verification is pending, certain features may be limited, including deposits or withdrawals above modest thresholds.
Ongoing Due Diligence and Risk Assessment
Xhjili maintains a risk-based approach to ongoing due diligence. Customer risk profiles are reviewed at onboarding and updated periodically or upon life events. High-risk indicators trigger enhanced monitoring and additional information requests.
Enhanced Due Diligence (EDD)
For accounts presenting elevated risk (for example, high-value activity, unusual patterns, or connections to high-risk jurisdictions), Xhjili conducts Enhanced Due Diligence, including additional documentation, ongoing monitoring, and frequency of review.
Transaction Monitoring and Suspicion Reporting
All activity is monitored for pattern deviations, unusual volumes, or transactions inconsistent with stated purpose. Suspicious activity is reviewed by the Compliance Team and, where required by law, reported to the competent authorities as a Suspicious Activity Report (SAR).
Data Collection, Retention and Privacy
Xhjili collects only information necessary to comply with AML/KYC obligations and to deliver services. Personal data is processed in accordance with our Privacy Policy. Retention of records related to customer due diligence and transactions shall be 5 years after account closure or longer if required by law. Data may be disclosed to regulators, law enforcement, payment service providers, and AML investigators in connection with regulatory obligations.
Sanctions, PEPs and Screening
We screen customers against applicable sanctions lists and Politically Exposed Persons (PEP) lists. If a match is identified, access may be suspended, the account blocked, or enhanced due diligence applied. Ongoing reviews include PEP status assessment and jurisdictional risk evaluation.
Self-Exclusion and Responsible Gaming
Xhjili supports self-exclusion as a preventive measure. Players may request fixed-term exclusions of 6 months, 1 year, or longer, up to permanent. During exclusion, access to all Xhjili products is blocked and funds are not accessible. Re-entry requires successful identity verification and completion of any applicable restoration steps.
Data Protection Rights and Security
Players have rights of access, correction, deletion (subject to legal retention). We implement appropriate security controls to protect personal data, including access controls, encryption, and incident response.
Roles and Responsibilities
- The Compliance Officer is responsible for the implementation, monitoring and updates of this policy.
- All staff receive AML/KYC training during onboarding and on an ongoing basis.
- Independent audits may be conducted to assess policy adequacy and effectiveness.
Policy Updates
We may amend this policy to reflect changes in law, regulation or risks. Material changes will be communicated to customers in a timely manner on the platform.
Contact Information
For questions about this policy or to submit information requests, contact: [email protected] and [email protected].