Effective Date: June 1, 2025
Applicable Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros
IOGr B.V. (referred to as the “Company”, “we”, “our”, or “us”) operates the website blink180true.com, together with all related subdomains, platforms, tools, and services (collectively, the “Website”).
This Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy describes the measures we apply to identify, verify, and monitor our business-to-business (“B2B”) clients in order to comply with regulatory requirements and to prevent money laundering, terrorist financing, fraud, or other unlawful activity.
1. Purpose and Applicability
The purpose of this Policy is to outline the Company’s KYC and AML framework and the controls we use to manage financial crime risk.
This Policy applies to all B2B counterparties, including but not limited to operators, resellers, platform providers, service integrators, and other corporate clients that engage with or use the Company’s services.
2. Risk-Based Approach
We apply a risk-based approach (RBA) during client onboarding and throughout the duration of the business relationship. Each client is assessed individually based on a range of risk factors, which may include:
- Country of incorporation and operational jurisdictions
- Ownership and control structure, including Ultimate Beneficial Owners (UBOs) and nominee arrangements
- Business model, product offerings, customer profile, and distribution channels
- Regulatory background and any adverse media exposure
- Transactional behavior and activity patterns, where available
Based on this assessment, clients are categorized under Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD). Risk assessments are reviewed at least annually and whenever material changes occur, such as ownership changes, restructuring, relocation, or licensing updates.
3. Due Diligence Requirements
3.1 Customer Due Diligence (CDD)
As part of standard onboarding, clients must provide accurate and up-to-date documentation (issued within the last three months where applicable), including:
- Certificate of Incorporation or official company registry extract
- Memorandum and/or Articles of Association
- Proof of registered business address (e.g., utility bill or bank statement)
- Corporate ownership structure clearly identifying shareholders and UBOs
- Identification documents for directors and UBOs holding more than 25% ownership:
- Government-issued photo identification (passport or national ID)
- Proof of residential address
3.2 Enhanced Due Diligence (EDD)
Enhanced Due Diligence is required where higher-risk indicators are identified, including but not limited to:
- Links to FATF high-risk or non-cooperative jurisdictions
- Complex, opaque, or layered ownership structures
- Involvement of Politically Exposed Persons (PEPs), or their close associates or family members
- History of regulatory breaches, sanctions exposure, or significant negative media
In such cases, additional information and verification may be requested, including:
- Source of Funds (SoF) and/or Source of Wealth (SoW) documentation
- Independent AML audit reports or formal compliance attestations
- Evidence of valid operating or gaming licences and certifications
- Expanded background checks, sanctions screening, and reputational assessments
4. Ongoing Monitoring
All B2B relationships are subject to continuous monitoring and periodic review, conducted at least once per year. Additional reviews may be triggered by significant events such as changes in ownership, jurisdiction, or regulatory status.
If unusual or potentially suspicious activity is identified, the Company may request further information, impose temporary restrictions, or suspend services while an investigation is conducted. Clients are required to promptly notify us of any changes that may affect their risk profile.
5. PEP and Sanctions Screening
Directors and UBOs are screened against internationally recognized sanctions and PEP databases, including but not limited to UN, EU, and OFAC lists, as well as reputable third-party data providers.
Confirmed matches or material adverse findings may result in enhanced due diligence, refusal of onboarding, suspension of services, and/or reporting to competent authorities where required.
6. Record Retention
The Company retains KYC and AML records, whether in physical or electronic form, for a minimum period of six (6) years following the termination of a business relationship, in accordance with applicable AML regulations of the Autonomous Island of Anjouan.
7. Restricted Jurisdictions
We do not establish or maintain relationships with clients that are registered in, owned or controlled by persons from, or otherwise associated with:
- FATF high-risk or non-cooperative jurisdictions
- Countries or regions subject to UN, EU, or OFAC sanctions
- The Union of the Comoros (in relation to white-label services targeting that jurisdiction)
- Any other territories restricted by the Anjouan Offshore Financial Authority
8. Non-Compliance
Failure to provide complete, accurate, or timely KYC/AML information may result in:
- Refusal to onboard
- Temporary suspension of services
- Termination of the business relationship
- Reporting to relevant authorities where legally required
9. Policy Updates
This Policy may be amended from time to time to reflect changes in legal, regulatory, or operational requirements. Where practicable, material changes will be communicated in advance. The most current version of the Policy will always be published on the Website and becomes effective upon posting unless otherwise stated.