AML & KYC Policy

1. Introduction

Drawzilla is committed to preventing money laundering, terrorist financing, fraud, sanctions evasion, and other financial crimes. We maintain a risk-based Anti-Money Laundering (AML) and Know Your Customer (KYC) program designed to protect our platform, our players, and the integrity of our services.

This AML Policy outlines the standards and procedures we apply when verifying player identities, monitoring transactions, assessing risk, and complying with applicable laws, regulatory requirements, and the conditions of our Anjouan Gaming Licence.

By creating an account or using Drawzilla, you agree to comply with this AML Policy and cooperate with any verification or compliance measures that may be required.

2. Our AML Commitment

Drawzilla is committed to maintaining a secure and compliant gaming environment. Our AML and KYC framework is designed to detect, prevent, and report activities that may involve money laundering, terrorist financing, fraud, or other unlawful conduct.

We apply a risk-based approach to customer due diligence, transaction monitoring, record keeping, and regulatory reporting. Our policies are regularly reviewed to ensure they remain aligned with applicable laws, international AML standards, and the requirements of our licensing authority.

3. Customer Due Diligence (CDD)

Before activating an account, Drawzilla collects basic customer information necessary to identify and verify each player. This may include your full legal name, email address, date of birth, residential address, and other information required to establish your identity.

Customer Due Diligence helps us confirm player eligibility, prevent fraudulent activity, and meet our legal and regulatory obligations. We may request additional information where necessary to verify the accuracy of the details provided.

4. Enhanced Due Diligence (EDD)

In certain circumstances, Drawzilla may apply Enhanced Due Diligence (EDD) before allowing continued use of our services or processing withdrawals.

EDD may be required based on factors such as transaction values, account activity, source of funds, higher-risk jurisdictions, or other risk indicators identified during our compliance reviews.

Where EDD is required, you may be asked to provide additional documentation or information. Failure to complete the requested verification may result in restrictions on your account until the review has been completed.

5. Identity Verification

To comply with regulatory requirements, Drawzilla may verify your identity at registration, before your first withdrawal, or whenever required by our compliance procedures.

Verification may include government-issued identification, proof of address, facial verification, or supporting documents relating to your source of funds. Identity verification is performed using trusted third-party providers, including Sumsub, together with our internal compliance processes.

Providing false, misleading, or fraudulent information may result in account suspension, closure, or reporting to the appropriate authorities.

6. Ongoing Monitoring

Drawzilla continuously monitors accounts and transactions to identify unusual or potentially suspicious activity.

Our monitoring processes may consider transaction patterns, account behaviour, deposit and withdrawal activity, wallet usage, device information, geographic risk, and other relevant factors. Reviews may be performed automatically or manually by our compliance team.

Where necessary, we may request additional information, temporarily restrict account activity, or conduct further investigations to ensure compliance with our legal and regulatory obligations.

7. Suspicious Activity Reporting

Drawzilla reserves the right to investigate any activity that appears suspicious or inconsistent with normal account behaviour.

Where required by law or regulation, we may submit reports to the appropriate regulatory, financial intelligence, or law enforcement authorities without notifying the affected user. We may also suspend transactions, delay withdrawals, or restrict account access while an investigation is ongoing.

These measures help protect Drawzilla, our players, and the wider financial system from unlawful activity.

8. Record Retention

Drawzilla maintains records relating to customer identification, identity verification, transactions, compliance reviews, and AML investigations in accordance with applicable legal and regulatory requirements.

These records are retained only for as long as necessary to satisfy our legal obligations, support regulatory inspections, resolve disputes, or investigate suspected financial crime.

When retention is no longer required, records are securely deleted or anonymized in accordance with our data management procedures.

9. Sanctions & Restricted Jurisdictions

Drawzilla does not offer its Services to persons located in, residing in, or accessing the platform from any prohibited jurisdiction.

The following jurisdictions are expressly prohibited under the conditions of our Anjouan Gaming Licence:

  • Australia
  • Austria
  • Union of the Comoros (including Anjouan)
  • France
  • Germany
  • Spain
  • United Kingdom
  • United States of America its territories possessions and dependencies

In addition, Drawzilla does not permit access from:

FATF High-Risk Jurisdictions (Blacklist)

  • Democratic People's Republic of Korea (North Korea)
  • Iran
  • Myanmar (Burma)

Comprehensive Sanctions Jurisdictions

  • Belarus
  • Cuba
  • Crimea Region
  • Donetsk People's Republic (DNR)
  • Luhansk People's Republic (LNR)
  • Iran
  • North Korea
  • Russia
  • Syria

Drawzilla also reserves the right to restrict or refuse access from any jurisdiction that:

  • is designated by the FATF as a High-Risk Jurisdiction subject to a Call for Action;
  • becomes subject to applicable sanctions imposed by the United Nations, OFAC, the European Union, the United Kingdom, or other competent authorities; or
  • is prohibited by the Anjouan Gaming Authority or applicable law.

It is your responsibility to ensure that your use of Drawzilla complies with the laws of your jurisdiction. You must not use VPNs, proxy services, or any technology intended to conceal or misrepresent your location. Drawzilla reserves the right to restrict, suspend, or terminate accounts that violate these requirements.

10. Your Responsibilities

By using Drawzilla, you agree to provide accurate, complete, and up-to-date information whenever requested.

You must not use the platform to conceal the origin of funds, conduct transactions on behalf of another person without authorization, submit false documentation, or engage in any activity that may violate applicable laws or this AML Policy.

You are responsible for cooperating with any compliance reviews and responding promptly to requests for additional information or documentation.

11. Changes to This AML Policy

Drawzilla may amend this AML Policy to reflect changes in legislation, regulatory requirements, industry standards, or our internal compliance procedures.

The latest version will always be available on our website and will become effective upon publication unless otherwise stated. Where required, we may notify users of material changes through the platform or by email.

Your continued use of Drawzilla after any changes take effect constitutes your acceptance of the updated AML Policy.

12. Contact Us

If you have any questions regarding this AML Policy or require assistance with identity verification or compliance matters, please contact us.

Operator

3-102-958035 SRL

Address

Canton 11 Garabito, Jacó, East side of the Municipality of Garabito, Bufete Sánchez Chavarría, Puntarenas, Costa Rica

Our compliance team will review enquiries and respond as promptly as reasonably practicable in accordance with our legal and regulatory obligations.