AML/KYC Policy

Anti-Money Laundering and Know Your Customer Policy

Last updated: 2026

Next scheduled review: 2027

1. Introduction

Sixty.gg is owned and operated by Nexora Ltd, registered under company number 15916, with its registered office at Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros. We hold an online gaming licence issued by the Offshore Finance Authority of the Autonomous Island of Anjouan, Licence Number ALSI-202501001-FI1.

Nexora Ltd is committed to the prevention of money laundering and the financing of terrorism. This AML/KYC Policy outlines our approach to ensuring compliance with applicable laws and our licensing obligations, including the FATF Recommendations, EU AML Directives (adopted as a benchmark of best practice), and the AML/CFT legislation of the Autonomous Island of Anjouan, Union of Comoros.

2. Objective

The objective of this Policy is to ensure that user identities are verified, financial activity on the platform is legitimate, and risks related to money laundering and terrorist financing are identified and mitigated. To achieve this, we operate an account verification process and ongoing transaction monitoring programme.

3. Legal Framework

This Policy aligns with:

• AML/CFT laws of the Autonomous Island of Anjouan, Union of Comoros
• FATF Recommendations
• EU Anti-Money Laundering Directives (5AMLD / 6AMLD), adopted as a benchmark of international best practice
• GDPR (Regulation (EU) 2016/679)
• Applicable international sanctions regimes, including those maintained by the UN, EU, and OFAC

4. Definition of Money Laundering

Money laundering involves concealing the origin of criminal proceeds, converting or transferring illicit assets to disguise their source, acquiring or using criminally obtained property, or aiding any of the above. It is a criminal offence regardless of where the underlying predicate offence occurred.

5. Governance

General Management of Nexora Ltd holds ultimate responsibility for AML/CFT compliance. An Anti-Money Laundering Compliance Officer (AMLCO) has been appointed to oversee the day-to-day implementation of this Policy, conduct risk assessments, review suspicious activity, manage reporting obligations, and ensure staff training remains current.

6. Customer Due Diligence (KYC)

We apply identity verification to all players. KYC is triggered in the following circumstances:

• Upon a player's first withdrawal request, regardless of amount
• When cumulative deposits reach $10,000 USD or equivalent
• When suspicious or unusual activity is detected on an Account, regardless of transaction amount
• At any other point where we consider verification necessary

Players will be required to provide:

• A valid government-issued photo ID - passport, national identity card, or driving licence (front and back where applicable)
• A selfie holding the ID document
• Proof of residential address - a bank statement or utility bill dated within the last three months
• Source of funds documentation, where required

Until KYC is completed, we may restrict deposits, withdrawals, and access to the Service. Failure to complete verification, or submission of false or fraudulent documents, may result in account closure, forfeiture of associated funds, and referral to the relevant authorities.

8. Transaction Monitoring

We employ a multi-layered transaction monitoring system to detect suspicious patterns on an ongoing basis. This includes automated monitoring, employee review of alerts, and manual audits of higher-risk accounts.

Indicators that may trigger a review include:

• Repeated deposits or withdrawals with little or no intervening gameplay
• Rapid cycling of funds
• Use of multiple wallets or payment methods inconsistent with normal behaviour
• Sudden changes in account activity, transaction volume, or geographic access patterns
• Wallet addresses or transactions flagged by blockchain analytics tools

We use third-party blockchain analytics tools to screen wallet addresses and transactions against sanctions lists, known illicit activity indicators, mixing and tumbling services, and other risk categories. Transactions flagged by these tools are subject to additional review and may be delayed, rejected, investigated, or reported.

All suspicious transactions are escalated to the AMLCO for review and a determination on whether a Suspicious Activity Report (SAR) should be filed with the relevant Financial Intelligence Unit (FIU).

9. Reporting Suspicious Activity

All personnel are required to report any suspicion of money laundering or terrorist financing to the AMLCO immediately. The AMLCO reviews all internal reports, files SARs with the relevant FIU where required, and applies any necessary account restrictions.

11. Record Keeping

In accordance with our legal obligations, the following records are retained for a minimum of ten (10) years following account closure or the completion of the relevant transaction:

• KYC documentation and player identification records
• Transaction records, including deposits, withdrawals, and wagers
• Suspicious activity reports and related compliance decisions

All records are stored securely in encrypted form, with access restricted to authorised personnel, and are available for production to regulatory authorities upon lawful request.

12. Staff Training

All personnel involved in the operation of the Service complete mandatory AML/CFT training upon commencement of their role and annually thereafter. Training is updated whenever there are material changes to applicable regulations or this Policy. Training covers red flag identification, CDD and EDD procedures, internal reporting obligations, and tipping-off restrictions.

13. Data Protection

All personal data collected and processed under this Policy is handled in accordance with our Privacy Policy and applicable data protection law. Player data collected for AML/KYC purposes is used solely for verification, fraud prevention, and regulatory compliance, and is not shared with third parties except where required by law or necessary to fulfil our regulatory obligations.

14. Contact

For AML or KYC-related enquiries, please contact us at support@sixty.gg.

Version: 1.0  |  Last reviewed: 2026  |  Next review: 2027