AML & Compliance Policy

Last updated: 14 October 2026 · Version 1.1 (draft)

Draft notice. This policy is a reference draft. DXAPlay is a B2B software vendor, not a gambling operator. The AML controls described here support our customers’ own AML obligations rather than imposing direct AML obligations on DXAPlay as a non-financial institution.

1. Our role

DXAPlay, a trade name of 3-102-954577 S.R.L., is a B2B software-as-a-service vendor serving the iGaming industry. We:

Do not hold player funds
Do not process gambling wagers or settle bets
Do not directly interact with end-players
Are not a financial institution under the laws of most jurisdictions

Our customers — the licensed gambling operators that integrate DXAPlay — are responsible for their own AML, CTF (counter-terrorist financing), KYC, and regulatory compliance under their gambling licenses. DXAPlay provides tooling that supports our customers’ compliance work; we do not substitute for it.

2. Customer onboarding (Know-Your-Business)

DXAPlay performs reasonable due diligence on prospective customers before granting paid access to the platform, including:

Verification of the customer’s legal entity status (company registration, beneficial ownership where applicable)
Verification of any gambling license(s) the customer claims to hold
Sanctions screening against OFAC, EU, UK, and UN consolidated lists for the entity and named principals
PEP (politically exposed person) screening for named principals
Risk-based review of the customer’s jurisdiction(s) of operation

3. Prohibited customers and use cases

DXAPlay does not provide service to:

Operators offering gambling in jurisdictions where they are not properly licensed or where their offerings are explicitly prohibited
Operators offering services to jurisdictions that are not permitted (US states without licensing, sanctioned countries, etc.) without appropriate geo-blocking and verification
Operators or principals appearing on sanctions or terrorism-finance lists
Operators primarily serving high-risk activities outside regulated iGaming (e.g. unregulated cryptocurrency exchanges, unlicensed financial services, illicit goods)

4. Tooling we provide for customer AML compliance

The platform provides built-in tooling that supports our customers’ AML programs:

KYC document handling — an integration point for KYC vendors such as Sumsub, Onfido, Persona and Veriff, plus staff document review
Sanctions & PEP flags — screening results from the customer’s provider are stored and surfaced in the operator admin
Responsible-gaming limits — per-player deposit, loss, session, and self-exclusion limits enforced at the money-action gate
Velocity & transaction-monitoring rules — configurable thresholds for suspicious deposit/withdrawal patterns (structuring, smurfing signals)
Multi-accounting detection — configurable risk rules for linked and duplicate accounts
Withdrawal review queue — manual approval workflow for high-risk or anomalous withdrawals
Append-only audit log — tamper-resistant record of every gate decision, status change, and compliance action
Source-of-funds documents — collected through the KYC document flow for high-value players
Per-jurisdiction reporting — format adapters for UKGC, MGA, GCB Curaçao, and other regulators (roadmap)

5. Internal AML safeguards

Within DXAPlay itself:

All employees and contractors with administrative access undergo background screening proportional to their role
Access to customer data is logged and reviewed
Payments to and from DXAPlay flow through verified, licensed banking partners
DXAPlay does not accept anonymous or cash payments
DXAPlay monitors its own platform for misuse and will suspend or terminate accounts that breach the Acceptable Use provisions of the Terms of Service

6. Cooperation with law enforcement and regulators

DXAPlay cooperates with valid law-enforcement and regulator requests. Customer audit logs and compliance trails are preserved for the periods required by applicable regulators (typically 5–7 years for iGaming). DXAPlay reserves the right, where legally permitted, to suspend access pending a lawful investigation.

7. Reporting suspicions

If you become aware of any actual or suspected misuse of the DXAPlay platform — including potential money laundering, terrorist financing, fraud, or sanctions violations — please report it confidentially to: compliance@dxaplay.com

8. Updates

This policy will be reviewed at least annually and updated as the platform’s capabilities and applicable law evolve.

9. Contact

Compliance contact: compliance@dxaplay.com