Effective Date: June 1, 2025
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros
This Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy explains the compliance principles and procedures applied by IOGr B.V. (“Company”, “we”, “our”, or “us”) in relation to the operation of chickenroad-official.ca, including all related websites, platforms, and services (collectively, the “Website”).
This Policy is intended to support regulatory compliance and to prevent the misuse of our services for money laundering, terrorist financing, fraud, or other unlawful activities.
1. Applicability and Scope
This Policy applies to all business-to-business (B2B) clients and partners that engage with the Company, including but not limited to:
- Online gambling operators
- White-label partners
- Platform providers and system integrators
- Distributors, resellers, and aggregators
- Other corporate counterparties
The Company does not provide services directly to individual players. Accordingly, this Policy does not apply to end-user customers.
2. Risk-Based Compliance Framework
The Company applies a risk-based approach to KYC and AML compliance. Each business relationship is assessed prior to onboarding and monitored throughout its duration to identify and manage potential financial crime risks.
Risk assessments may consider factors such as:
- Jurisdiction of incorporation and operational presence
- Ownership and control structure, including Ultimate Beneficial Owners (“UBOs”)
- Business activities, product offerings, and target markets
- Licensing status and regulatory oversight
- Reputational considerations and adverse media
- Transaction patterns, where applicable
Clients are classified as standard risk or higher risk based on this assessment. Risk profiles are reviewed at least annually and whenever material changes occur.
3. Customer Due Diligence (CDD)
Before establishing a business relationship, all clients must complete Customer Due Diligence.
As part of the CDD process, the Company may request documentation including:
- Certificate of Incorporation or equivalent registration document
- Extract from an official commercial or trade register
- Articles and/or Memorandum of Association
- Proof of registered business address
- Corporate ownership and control structure chart
- Identification details of directors and senior management
For each Ultimate Beneficial Owner holding 25% or more ownership or control, the following documentation is required:
- Valid government-issued photo identification
- Proof of residential address
All documentation must be accurate, complete, and up to date, typically issued within the last three (3) months where applicable.
4. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied where a higher risk of financial crime is identified.
Circumstances that may trigger EDD include:
- Connections to jurisdictions identified as high-risk or non-cooperative by the FATF
- Complex, layered, or opaque ownership structures
- Involvement of Politically Exposed Persons (PEPs), their close associates, or family members
- Prior sanctions exposure, regulatory enforcement actions, or significant adverse media
EDD measures may include:
- Verification of Source of Funds (SoF) and Source of Wealth (SoW)
- Confirmation of valid operating or gaming licences
- Independent AML or compliance audit reports
- Expanded sanctions, PEP, and reputational screening
The Company reserves the right to refuse onboarding or terminate relationships where risks cannot be adequately mitigated.
5. Ongoing Monitoring
All active client relationships are subject to continuous monitoring to ensure ongoing compliance with KYC and AML obligations.
Monitoring activities may include:
- Periodic review of KYC documentation
- Event-driven reviews following changes in ownership, management, jurisdiction, or licensing
- Assessment of unusual or inconsistent activity
Clients are required to promptly notify the Company of any changes that may affect their risk profile.
6. Sanctions and PEP Screening
The Company screens directors, shareholders, and UBOs against applicable international sanctions and PEP databases, including those maintained by the United Nations, European Union, and OFAC, as well as reputable third-party screening providers.
Positive matches or material adverse findings may result in enhanced due diligence, suspension of services, refusal of onboarding, or reporting to relevant authorities where required by law.
7. Record Retention
KYC and AML records are retained securely in electronic or physical form for a minimum of six (6) years following the termination of the business relationship, in line with applicable regulatory requirements.
8. Restricted Jurisdictions
The Company does not establish or maintain business relationships with entities that are:
- Registered in, operating from, or controlled by FATF high-risk or non-cooperative jurisdictions
- Subject to United Nations, European Union, or OFAC sanctions
- Operating within the Union of the Comoros for white-label services targeting that jurisdiction
- Otherwise restricted by the Anjouan Offshore Financial Authority
9. Consequences of Non-Compliance
Failure to provide accurate, complete, or timely KYC/AML information may result in:
- Refusal to onboard
- Temporary or permanent suspension of services
- Termination of contractual relationships
- Reporting to regulatory or law enforcement authorities where legally required
10. Policy Updates
This Policy may be amended periodically to reflect changes in applicable laws, regulations, or internal compliance practices. The most current version will always be available on the Website and becomes effective upon publication unless stated otherwise.