Aml Policies

Purpose and Scope

The Anti-Money Laundering (AML) policies of Dada8 establish a risk‑based program to prevent, detect, and report money laundering and terrorist financing activities. The policies govern all user accounts, registrations, deposits, withdrawals, and related activities conducted on the Dada8 platform, and require cooperation with competent authorities in accordance with applicable AML regulations.

These policies apply to all users and activities across Dada8 offerings. They are designed to ensure compliance with legal and regulatory requirements and to maintain the integrity of the platform, including the protection of user funds and information.

Governance and Oversight

Dada8 designates a Money Laundering Compliance Officer (MLCO) responsible for the implementation, maintenance, and ongoing update of AML controls. The MLCO oversees internal communications, ensures staff training on AML procedures, and coordinates periodic reassessment of policies and controls. Reassessment occurs at least annually and more frequently as required by changes in products, technology, customer demographics, or regulatory developments.

The MLCO maintains ownership of risk assessment, escalation pathways, and reporting to senior management. Dada8 reserves the right to cooperate with regulatory or governmental authorities and to provide information and documentation as legally required.

Know Your Customer (KYC) and Verification

On registration, Dada8 requires the prospective user to provide mandatory information, which must be true and correct: full name, date of birth, residential address, valid email address, phone number, and relevant payment information. The user warrants accuracy of the information provided and acknowledges that inaccuracies may result in account suspension or closure.

  • Identity verification: The user must provide a government‑issued identity document (e.g., passport or national ID) and, where required, a photograph of the user holding the document to confirm identity.
  • Address verification: The user must provide proof of address consistent with the information on file (e.g., utility bill, bank statement) dated within a recent period specified by Dada8.
  • Payout verification: For withdrawal requests, the user must submit acceptable identity and address verification documents before processing payouts, and verification results must be approved under the MLCO’s authority.
  • Account uniqueness: The user must not hold more than one active Member Account. If multiple accounts are detected, all accounts may be blocked or closed and any bets or winnings may be voided at Dada8’s discretion.
  • Payment instrument integrity: For card deposits, the name on the card must match the account holder; for electronic wallets, the registered email must match the account. Dada8 does not accept anonymous or unverified payment instruments, and withdrawals to unassociated instruments are prohibited.
  • Ongoing verification: In certain cases, additional proof of identity or address may be requested after account activation, particularly when the user becomes active or engages in high‑risk activity.

Risk Assessment and Ongoing Monitoring

Dada8 applies a risk‑based approach to customer due diligence and ongoing monitoring, aligned with FATF‑style standards. The following risk categories inform the level of scrutiny and controls:

  • Country/Geographic risk: evaluation of the user’s residence jurisdiction for AML/CFT adequacy, sanctions status, and reputational risk.
  • Customer risk: assessment of factors such as Politically Exposed Persons (PEPs), sanctions exposure, and indicators of suspicious behavior.
  • Transaction risk: assessment of spend patterns, frequency, and method of payment to identify disproportionate or unusual activity relative to the user profile.

Standard Verification is applied based on activity thresholds or risk indicators. The MLCO may require enhanced due diligence if risk is elevated or if indicators suggest potential non‑compliance with AML/CFT obligations. The threshold for triggering verification is the total amount of transactions conducted on the platform by a user reaching or exceeding USD 1,000, unless higher risk factors justify earlier review.

Enhanced Due Diligence for PEPs and High‑Risk Jurisdictions

  • Where a user is a Politically Exposed Person (PEP) or resides in a high‑risk jurisdiction, Dada8 applies Enhanced Due Diligence (EDD). This may include additional documentation, confirmation of source of funds and wealth, and closer scrutiny of account activity.
  • Final approval of enhanced verification requires senior management authorization. Dada8 may request information on the user’s source of wealth, employment details, and other data consistent with regulatory expectations.
  • In cases where documentation is refused or incomplete, Dada8 may escalate to regulatory authorities as permitted by law.

Activity Monitoring

Dada8 monitors all user activities to detect suspicious patterns or behaviors. Indicators of suspicious activity include, but are not limited to, the following:

  • Use of multiple cards or payment agents in rapid succession;
  • Consistent errors or unusual payment codes during processing;
  • Payment instruments issued by different entities or located in different regions;
  • Rapid changes in payment methods or devices within a short period;
  • Reluctance to undergo verification or to provide requested information;
  • Geolocation discrepancies between citizenship/residency, IP address, and device identifiers;
  • Device ID matching across multiple accounts.

If suspicious activity is identified, the matter is directed to the anti‑fraud department for risk assessment and further action, which may include escalation to the MLCO and appropriate regulatory authorities where warranted.

Transactions Monitoring and Payment Integrity

  • Card transactions: the name on the card must equal the account holder’s name; third‑party card use is prohibited.
  • Electronic wallets: the wallet email must match the account email used during registration.
  • Deposits from a payment instrument must be traceable to the user; withdrawals must be made to the same verified instrument or to a bank account that can be reliably linked to the user.
  • Dada8 does not accept payments from anonymous instruments (e.g., untraceable wallets) and does not permit withdrawals to third‑party instruments.

Record‑Keeping and Data Protection

Dada8 retains documents and data obtained during verification, along with transaction data and supporting evidence, in accordance with applicable AML statutes and data protection laws. Retention includes the documents listed in verification sections and follows the higher of regulatory retention periods, GDPR requirements, and internal policy.