Purpose and Scope
Xhjili maintains this AML CFT policy to prevent and detect money laundering, terrorist financing and related predicate offenses in all products and services offered by Xhjili. This policy applies to all customers, onboarding activities, account management, and all transactions conducted through any channel.
Regulatory Framework and Supervisory Authority
Xhjili complies with all applicable anti money laundering and countering financing of terrorism laws and regulations. The company operates under the supervision of the competent supervisory authority and, where applicable, the Financial Intelligence Analysis Unit. This policy is reviewed and updated to reflect legal and regulatory changes and to maintain an effective risk based approach.
Definitions
- Anti Money Laundering AML means activities aimed at preventing the conversion of illicit funds into legitimate resources.
- Countering the Financing of Terrorism CFT means measures to prevent funds from being used to support extremist or terrorist activities.
- KYC Know Your Customer refers to the identification and verification of a customer’s identity and risk profile.
- CIP Customer Identification Program encompasses the procedures for verifying identity during onboarding.
- CDD Customer Due Diligence is the initial level of due diligence proportional to risk.
- EDD Enhanced Due Diligence is heightened verification for higher risk customers.
- SOF Source of funds documentation may be requested to verify the origin of funds used in transactions.
- PEP Politically Exposed Person denotes a customer who may require enhanced scrutiny due to public position.
- SAR Suspicious Activity Report is a report made to the competent authority when suspicious activity is detected.
Customer Identification and Verification
On registration and prior to enabling gambling activities, customers must provide accurate information including full legal name, date of birth, residential address and government issued identification. Verification will be conducted using reliable sources and may require additional documents. Identity verification must be completed within thirty (30) days from account creation. Accounts not verified within the period may be restricted or closed and funds may be withheld pending verification. Accounts must be used solely by the individual to whom they belong; sharing or transferring an account is prohibited and may result in account lockout and forfeiture of funds.
Risk Based Due Diligence
Xhjili applies Customer Due Diligence based on the risk assessment of each customer. Low risk customers undergo standard verification; higher risk customers, including those exhibiting unusual or large transactions, customers from high risk jurisdictions, or those with enhanced due diligence indicators, will be subject to enhanced verification procedures and ongoing monitoring. The Company may request additional information such as source of funds and source of wealth and may require periodic re-verification based on risk factors.
Enhanced Due Diligence
For customers assessed as high risk, Xhjili implements Enhanced Due Diligence measures. This may include additional identity validation, independent verification through third parties, assessment of source of funds and source of wealth, and, in exceptional cases, site visits or additional documentation. Decisions to apply EDD are recorded and reviewed by the Compliance Officer.
Ongoing Monitoring and Reporting
Xhjili conducts ongoing monitoring of customer accounts and transactions using risk based controls to identify unusual or suspicious activity. Transaction monitoring may include velocity checks, large value transfers, and patterns involving high risk jurisdictions or persons. Where thresholds or indicators are met, activities will be escalated for enhanced review. Suspected illicit activity will be reported to the competent authorities in accordance with applicable law. The Company maintains records of all SARs and internal investigations as required by law.
Account Restrictions for Non Verified Users
Accounts that are not verified in accordance with the verification timeline may be limited in functionality. Such accounts may be restricted from depositing or withdrawing funds or from transacting in certain services until verification is completed. Verification completion reinstates full access in a timely manner consistent with regulatory obligations.
Data Retention and Record Keeping
Xhjili retains all customer identification data, transaction records and related documents for the period required by applicable law and regulation. Records are maintained securely and access is restricted to authorized personnel. Retention periods shall comply with local legal requirements and industry standards, typically extending for several years after account closure.
Compliance Governance
The Company designates a Compliance Officer responsible for the AML CFT program. The officer has independent authority, reports to senior management, and oversees policy implementation, risk assessment, and compliance with regulatory requirements. The Compliance Officer coordinates internal controls, monitoring, and reporting to relevant authorities as required by law.
Training and Awareness
All employees and relevant personnel receive regular AML KYC training. Training covers identification of risk indicators, customer verification procedures, escalation pathways, and handling of suspicious activity reports. Training records are maintained to demonstrate ongoing compliance.
Third Party Service Providers
Third party service providers engaged by Xhjili must comply with this AML CFT policy. The Company conducts due diligence before onboarding providers and requires contractual commitments to AML CFT compliance. Information sharing with providers is limited to what is necessary for compliance and regulatory purposes, subject to applicable data protection laws.
Review and Updates
This policy is reviewed at least annually and updated to reflect regulatory changes, operational developments and risk assessments. Material changes are communicated to staff and incorporated into training and procedures with appropriate version control.
Data Privacy and Cooperation with Authorities
Personal data processed for AML CFT purposes is handled in accordance with applicable privacy laws. Xhjili cooperates with competent authorities, providing information as legally required and based on a lawful basis. Information requests are assessed for necessity, proportionality and data minimization.
Contact and Escalation
Customers may contact the Compliance Office for questions about AML CFT requirements or to submit documents. All inquiries are handled in accordance with applicable internal procedures and data protection standards.