666d applies a risk‑based approach to anti‑money laundering and countering the financing of terrorism (AML/CFT). The policy governs customer identification, due diligence, ongoing transaction monitoring, sanctions compliance, reporting of suspicious activity, and the governance framework by which these activities are overseen. The objective is to prevent misuse of 666d platforms for illicit finance while ensuring legitimate customer activity may proceed with appropriate verification and oversight.
On onboarding, the customer must provide verifiable information to establish identity and residence. The minimum information includes full legal name, date of birth, permanent residential address, nationality, and government supplied identification documents. Additional information may be requested based on risk assessment results, product type, or transactional behaviour.
Documentation must be provided within the timeframes specified in this policy. Failure to provide complete and verifiable information may result in limitations on access or termination of services.
The customer must ensure that payment methods used are registered to the customer’s name. If a payment is issued from an account not in the customer’s name, 666d reserves the right to terminate the account or invalidate related transactions and winnings.
666d employs three elements of verification at onboarding and as part of ongoing due diligence:
Where required, the customer may be asked to provide photographs or video verifying possession of documents or payment instruments. Onboarding may include assessment of occupation or business activity and source of funds where appropriate.
Documents may be submitted through secure channels designated by 666d. If requested documents are not provided within the stipulated period, access to services may be restricted pending verification.
666d applies CDD on a risk‑based basis. Three tiers of diligence are used:
EDD measures may include additional documentation, more frequent review, and biometric identity checks. Records of CDD and EDD activities are retained in accordance with data retention requirements.
666d conducts continuous monitoring of customer activity and transactions to detect suspicious or unusual patterns. Monitoring combines automated systems with manual oversight by the Compliance team.
666d screens customers and transactions against sanctions lists and maintains a current list of prohibited or high‑risk jurisdictions. Enhanced diligence or restrictions apply for customers from those jurisdictions. False positives are managed through manual review prior to any action. Immediate actions include freezing or restricting accounts and initiating investigations in accordance with internal protocols and applicable law.
666d provides AML/CFT training to all employees. Training covers red flags, reporting processes, and regulatory obligations. Key personnel receive advanced training aligned with their duties. The governance framework assigns roles and responsibilities to the Board, the Compliance Officer, and Internal Audit to ensure ongoing effectiveness of controls, risk assessments, and corrective actions.
Records relating to customer identification, due diligence, and transaction monitoring are retained for a minimum of five years from the date of the last customer activity, or longer as required by law. Access to personal data is restricted to authorized personnel in the course of performing AML/CFT duties and is subject to applicable data protection obligations.
The Board retains oversight of the AML/CFT program, approving policies, risk frameworks, and internal controls. The Compliance Officer develops and maintains policies, conducts risk assessments, and leads training and monitoring activities. Internal Audit performs independent assessments of controls and effectiveness, reporting findings to the Board. Management ensures resource allocation and timely implementation of corrective actions.
Anti‑Money Laundering (AML) — a set of policies and procedures designed to prevent money laundering. Counter‑Terrorist Financing (CFT) — measures to prevent financing of terrorist activities. Customer Due Diligence (CDD) — process of identifying customers and assessing risk. Enhanced Due Diligence (EDD) — additional measures for high‑risk customers. Source of Funds — funds used to finance a specific transaction. Source of Wealth — the customer’s overall wealth origin. Sanctions — legal restrictions imposed by governments and international bodies. Politically Exposed Person (PEP) — an individual in a prominent public role or a related individual with elevated risk. Transaction Monitoring — ongoing review of transactions to identify illicit activity. SAR — Suspicious Activity Report filed with the appropriate authorities. By adopting these provisions, 666d commits to maintaining robust controls and transparent processes in line with regulatory expectations and industry best practices.