AML & KYC Policy

1 Introduction and Purpose

Bolt is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures for preventing, detecting, and reporting money laundering activities and other financial crimes.

Our AML/KYC program is designed to comply with international standards and best practices, including recommendations from the Financial Action Task Force (FATF) and applicable regulatory requirements.

2 Scope and Application

This policy applies to:

• All customers of Bolt
• All employees, contractors, and agents
• All products and services offered on our platform
• All transactions, regardless of amount or cryptocurrency type

3 Know Your Customer (KYC) Requirements

Level 1 - Basic Verification

Required for all accounts:

• Valid email address verification
• Acceptance of Terms and Conditions
• Age confirmation (18+ or legal gambling age)

Level 2 - Identity Verification

Required for withdrawals above threshold limits:

• Government-issued photo ID (passport, national ID, or driver's license)
• Selfie with ID document
• Full name and date of birth verification

Level 3 - Enhanced Verification

Required for high-value accounts or upon request:

• Proof of address (utility bill, bank statement - less than 3 months old)
• Source of funds documentation
• Source of wealth declaration
• Additional documentation as required

4 Customer Due Diligence (CDD)

We perform due diligence on all customers, which includes:

• Verifying customer identity using reliable documents
• Screening against sanctions lists and PEP databases
• Assessing and documenting customer risk profiles
• Understanding the nature and purpose of the business relationship
• Ongoing monitoring of transactions and behavior

5 Transaction Monitoring

We employ sophisticated monitoring systems to detect suspicious activity, including:

• Automated transaction monitoring with risk-based alerts
• Pattern analysis for unusual betting or deposit behavior
• Blockchain analytics for cryptocurrency transactions
• Velocity checks on deposits and withdrawals
• Cross-referencing with known fraud indicators

6 Red Flags and Suspicious Activity

Indicators that may trigger enhanced review include:

• Deposits significantly exceeding normal gaming patterns
• Frequent deposits followed by minimal play and withdrawal requests
• Use of multiple cryptocurrency wallets with no clear purpose
• Transactions linked to known high-risk addresses or mixers
• Reluctance to provide verification documents
• Inconsistent information provided during verification
• Transactions inconsistent with stated source of funds
• Structuring deposits to avoid verification thresholds

7 Reporting Obligations

When suspicious activity is identified, we are obligated to:

• File Suspicious Activity Reports (SARs) with relevant authorities
• Maintain confidentiality of reports (tipping-off is prohibited)
• Cooperate fully with law enforcement investigations
• Preserve all records related to reported activity

We do not inform customers when reports are filed, as this is prohibited by law.

8 Record Keeping

We maintain comprehensive records including:

• Customer identification documents and verification records
• Transaction records (deposits, withdrawals, bets)
• Risk assessments and due diligence findings
• Suspicious activity reports and investigation files
• Training records for employees

Records are retained for a minimum of 5 years after the end of the business relationship or completion of the transaction, whichever is later.

9 Prohibited Jurisdictions

We do not accept customers from jurisdictions subject to comprehensive sanctions or where online gambling is prohibited. These include but are not limited to:

• United States and its territories
• United Kingdom
• Countries under OFAC, EU, or UN sanctions
• Other restricted jurisdictions as determined by our compliance team

10 Staff Training and Awareness

All employees receive:

• Initial AML/KYC training upon joining
• Regular refresher training and updates
• Role-specific training for compliance and support staff
• Updates on new regulations and emerging risks

11 Customer Obligations

As a Bolt customer, you agree to:

• Provide accurate and truthful information
• Complete verification requests promptly
• Notify us of any changes to your personal information
• Use only funds that belong to you and were obtained legally
• Not use our platform for money laundering or illegal activities

Failure to comply may result in account restrictions, closure, and reporting to authorities.

12 Contact Compliance Team

For questions about our AML/KYC procedures or to report concerns: