Kyc & Aml Policies

Purpose and Scope

Ph operates an online gambling platform and applies a policy for customer identity verification and anti money laundering controls. This KYC and AML Policy governs how Ph verifies users, screens for fraud and illicit activity, and conducts ongoing monitoring to comply with applicable laws and regulatory requirements. It applies to all users who open accounts, deposit funds, place wagers, or engage in any financial transaction on Ph services.

Regulatory Framework and Risk Based Approach

Ph uses a risk based approach to identity verification and anti money laundering measures. Verification is performed in proportion to assessed risk, with enhanced due diligence for higher risk scenarios. Ongoing monitoring of transactions and account activity is conducted to identify and address unusual or suspicious behavior in accordance with law and regulatory expectations.

Triggers for Identity Verification

Ph may request verification in the following circumstances and at other times as appropriate: suspicion of fraud or money laundering or other criminal activity; doubts about the authenticity or validity of documents provided; breach of Ph terms or conditions; or any situation the Company deems appropriate for compliance purposes. During verification, Ph may restrict withdrawals from the User’s Account.

Legal Age and Compliance Consequences

Ph will verify that the user meets the legal age requirement for gambling. If it cannot confirm the user is of legal age, the Account may be suspended. If it later becomes known that the user was under the legal age at the time of any gambling or gaming transactions, the following consequences apply: the Account will be closed; all transactions conducted during that period are void; deposits made during that period will be returned to the source; any winnings accrued during that period will be forfeited; the user may be required to return to Ph any funds previously withdrawn.

Minimum Identity Data

The minimum data required to verify a customer includes: full name; date of birth; citizenship; residential address; and an identifying number provided by a government authority.

Required Identity Documents

The standard documents that Ph may request are: an in person or government issued identity document such as a passport or national ID card; a document proving the residential address currently in use (for example a recent utility bill or bank statement).

Additional Verification Documents

Ph may request supplementary documents when necessary, including one or more of: additional national identity documents (driver’s license, military ID, etc.); photographs of the user holding the ID against a readable background; a photo of the bank card used for transactions (showing readable card numbers with the first five digits and the last four digits, cardholder name, and expiry date).

Source of Funds Verification

Ph may require evidence of the source of funds used for gambling or deposits. Acceptable evidence may include: payslips or remuneration statements; bank statements showing regular inflows from identifiable sources; a trust deed with clear entitlement; or dated proof of a specific payment or award to the user. The information provided must clearly identify the actual source(s) of funds used for play or wagering.

Document Acceptance and Rejection

Documents provided by the user will be rejected if: the name or address does not match the account records; documents are illegible or copies are unclear; the document is not among accepted identification documents; or for any other reason determined appropriate by Ph staff. Ph reserves the right to require additional documents as part of the verification process.

Decision and Compliance Outcome

Following analysis of the submitted documents, Ph shall determine the appropriate course of action in line with the Terms and Conditions, Privacy Policy, License Agreement, and applicable law. The outcome may include verification approval, continued verification checks, or account restrictions as permitted by policy and law.

Obligations and Record Keeping

Ph maintains due diligence records for all verified customers and retains data in accordance with applicable legal obligations. The Company keeps essential identity and transaction records for audit, reporting, and regulatory review as required by law.

Anonymous and Nom de Plume Accounts

Anonymous or nominal accounts are not permitted. If an account is suspected of lacking verifiable identity or is identified as nom de plume, Ph shall conduct appropriate due diligence to establish bona fides. If identity cannot be determined, the account shall be closed, winnings cancelled, and deposits returned to the originating source or otherwise disposed of in a compliant manner.

Duplicate and Linked Accounts

Ph will identify and associate accounts that may be owned or controlled by the same individual. Ph may cancel additional accounts, suspend or terminate the affected accounts, cancel winnings derived from linked activity, and return deposits to the owner of the account as permitted by policy and law.

Politically Exposed Persons

Ph applies a risk based approach to customers who are Politically Exposed Persons or who are linked to such persons. The Company will identify PEPs through customer questionnaires and internal checks. Based on risk, Ph reserves the right to decline new applications or terminate ongoing services without further explanation where a breach of KYC or AML policy is suspected or confirmed, or where required by law.

Ongoing Monitoring and Data Updates

Ph continuously monitors customer transactions and account activity. Customers must promptly update personal details or documentation if changes occur, and may be required to provide updated verification materials as part of ongoing compliance checks.

Data Protection, Retention, and Confidentiality

Ph handles all personal data in accordance with its Privacy Policy and applicable data protection laws. Data is retained only as long as necessary to fulfill verification, anti money laundering, and regulatory obligations, and is protected against unauthorized access or disclosure.

User Rights, Refusal, and Termination

Ph reserves the right to refuse admission, suspend, or terminate accounts, and to impose verification demands or transaction restrictions as permitted by law and this Policy. Users may be required to provide additional information to maintain compliance under this Policy.

Policy Updates and Notice

Ph may update this Policy from time to time to comply with changes in law or regulatory expectations. Users will be notified of material changes through the platform in accordance with applicable notice requirements.

Support and Contacts

For questions or to initiate verification, users should contact Ph support via the in platform Help Center. The Support team will respond in accordance with internal service standards and applicable law.