Introduction
7i777 operates as a remote gaming entity and is subject to anti‑money laundering and countering the financing of terrorism obligations. This KYC Policy sets the standards for customer due diligence, identity verification, ongoing monitoring, record‑keeping and reporting to prevent 7i777 from being used for financial crime.
Scope
This policy applies to all customers, including individuals and legal entities, and to all channels by which 7i777 provides its services, including online onboarding and ongoing relationships. It governs the collection, verification and maintenance of information required to assess and mitigate money laundering and financing of terrorism risks in accordance with applicable law and guidance.
Legal Framework and Supervisory Authority
7i777 complies with the regulatory framework applicable in Curaçao, including the National Ordinance on Hazard games of Curaçao (NORUT) and the NOIS, and with internationally recognized guidance relating to AML/CFT. The company remains subject to supervision by the competent supervisory authority, and to all applicable reporting and examination requirements. The NOIS requires subject persons to maintain customer due diligence measures, record‑keeping procedures and internal reporting procedures in relation to business relationships and transactions.
Policy Governance and Responsibility
The ultimate responsibility for 7i777's AML/KYC policy rests with the Director. The policy is approved by the Board and is reviewed at least annually or when regulatory changes require updates. 7i777’s governance framework ensures escalation of material risk and compliance matters to senior management and the Board.
Definitions
Customer due diligence (CDD) means the measures taken to identify and verify a customer, understand the purpose and intended nature of the business relationship, and assess risk. Enhanced due diligence (EDD) means additional verification, monitoring and controls applied to higher‑risk customers, products, services or geographies. Suspicious activity refers to any transaction or pattern of activity that reasonably indicates potential money laundering or terrorist financing.
Customer Due Diligence
7i777 applies a risk‑based approach to CDD in onboarding and throughout the business relationship. Key elements include identity verification, assessment of purpose and intended nature of the relationship, and documentation of the customer risk profile.
- Identity verification prior to establishing a business relationship, or within a defined onboarding window if non‑face‑to‑face onboarding is used;
- Verification of identity using reliable, independent sources and, where appropriate, third‑party verification solutions;
- Identification of beneficial owners and control structures where the customer is a legal entity;
- Determination of the purpose and intended nature of the business relationship, including expected transaction types and volumes;
- Maintenance of records and documentation sufficient to demonstrate compliance with CDD requirements.
Non‑Face‑to‑Face Onboarding
Where onboarding occurs without physical presence, 7i777 applies validated remote verification methods, supplements identity checks with additional documentation when required, and assigns risk‑based monitoring to the onboarding decision.
Enhanced Due Diligence
EDD is applied where risk indicators are present, including high‑risk jurisdictions, complex ownership structures, politically exposed persons, unusual transactional patterns, or high‑risk products. EDD measures may include enhanced identity verification, source of funds and source of wealth verification, additional information on the expected business activity, and ongoing management approval for ongoing relationship changes.
Ongoing Monitoring and Review
All customers are subject to ongoing due diligence. 7i777 monitors transactional activity and updates customer information at defined intervals and when material changes occur. Re‑verification and risk profile updates are conducted in line with the risk assessment outcome and regulatory expectations.
Risk Assessment and Risk‑Based Approach
7i777 operates a risk‑based framework to identify, assess and mitigate ML/FT risk. The risk model considers:
- Customer risk (including identity verification and ownership structure);
- Product and service risk (types of games, payouts, and payment methods);
- Interface risk (online channels and digital access points);
- Geographic risk (jurisdictional risk and cross‑border activity).
The risk assessment governs the level of due diligence, the frequency of reviews, and the scope of ongoing monitoring. Assessments are performed at onboarding and reviewed monthly thereafter, with material changes triggering immediate reassessment.
Record‑Keeping and Data Retention
7i777 maintains all records related to customer identity, due diligence, transactions and internal reports for the period required by applicable law and supervisory guidance. Records are maintained in a form that permits examination by the supervisory authority and undercover investigations as required by law.
Internal Controls, Training and Awareness
Staff are trained in AML/CFT laws, 7i777 policies, and the recognition of suspicious activity. Training is completed prior to engagement and updated in response to regulatory changes or business expansions. Training records are maintained by the Compliance function and are available for audit.
Suspicious Activity Reporting and Internal Reporting
Employees must promptly report suspicious activity through established internal channels. 7i777 will file reports to the competent supervisory authority or financial intelligence unit in accordance with NOIS and related laws, while preserving the integrity of investigations and ensuring no tipping off of customers.
Policy Review and Regulatory Change
The policy is reviewed at least annually and whenever regulatory changes occur, including updates to NORUT, NOIS or related guidance. The Board receives periodic compliance and risk management updates detailing policy effectiveness and residual risk.
KYC Processing Flow
- Initiate customer inquiry and perform initial risk screening;
- Collect identity information and verify identity prior to establishing the business relationship;
- Determine applicable CDD level based on risk assessment;
- Apply enhanced due diligence for identified high‑risk cases;
- Approve or reject onboarding based on verification outcomes;
- Implement ongoing monitoring and schedule periodic re‑verification as risk dictates;