Kyc & Aml Policies

Scope and Purpose

STARPH operates a KYC and AML program designed to prevent money laundering and the financing of illicit activity, ensure regulatory compliance, protect customers, and preserve the integrity of STARPH's operations. This policy applies to all STARPH customers and prospective customers and governs onboarding, verification, ongoing monitoring, and reporting of suspicious activity. STARPH shall comply with applicable laws and regulations and may update this policy as required by changes in risk, products, or jurisdictional requirements. All customers must be at least 18 years old to use STARPH services.

Definitions

• Anti Money Laundering (AML): measures to detect, deter and report money laundering and related abuses.
• Know Your Customer (KYC): procedures to verify the identity and assess the risk associated with a customer.
• Source of Funds (SOF): the origin of the funds used in customer transactions.
• Source of Wealth (SOW): the origin of the customer’s overall wealth, used for enhanced due diligence.
• Politically Exposed Person (PEP): an individual who holds or has held a prominent public function and may require enhanced scrutiny.
• High risk jurisdiction: a country or region identified as having higher risk for money laundering or terrorist financing.

Governance and Oversight

STARPH maintains an AML program led by an AML Compliance Officer who reports to senior management. The AML Officer is responsible for implementing the policy, conducting risk assessments, coordinating training, and ensuring ongoing compliance. Senior management shall provide resources, approve material changes, and supervise the program. Data retention, record keeping, and reporting obligations shall be aligned with applicable law and regulatory expectations.

Onboarding and Identity Verification

STARPH applies a tiered verification framework to establish customer identity and assess risk before enabling full transactional capabilities. The process comprises three verification steps described below. Verification is required for all new customers and may be repeated or escalated as needed based on risk indicators.

• Step 1 — Initial Verification (all customers):
  • Collect: full name, date of birth, residential address, valid email, contact number, nationality, and preferred payment method.
  • Document verification: submission of government-issued identification and a current address document; verification may include automated checks and manual review.
  • Outcome: account may be opened with limited capabilities or with withdrawal restrictions pending verification; false or misleading information will result in account closure and forfeiture of any winnings as permitted by policy.
• Step 2 — Intermediate Verification (triggered by activity thresholds):
  • Trigger: deposits or withdrawals exceeding 2,000 USD or transfers to another user exceeding 1,000 USD.
  • Requirements: upload of a verifiable government-issued ID and a proof of address; conduct dual verification checks, including an electronic verification against trusted data sources and a manual review if the electronic check is inconclusive.
  • Restriction: until Step 2 is completed, deposits and withdrawals may be partially restricted or held in escrow in STARPH's discretion.
• Step 3 — Enhanced Verification (higher-risk activity or higher thresholds):
  • Trigger: deposits or withdrawals exceeding 5,000 USD or transfers to another user exceeding 3,000 USD.
  • Requirements: source of funds documentation, including but not limited to bank statements, employer letter, corporate documents for business owners, or tax records; potential third-party verification and guidance from the AML Officer.
  • Restriction: transactions may be blocked or require explicit clearance before processing; higher levels of scrutiny apply to high-risk customers or unusual patterns.

Third-Account Prohibition

Customers may not hold more than one active STARPH account. If multiple accounts are detected, STARPH may close all related accounts and void any bets or winnings in its discretion, subject to applicable laws and regulatory guidance.

Ongoing Monitoring and Transaction Surveillance

STARPH conducts ongoing monitoring of customer activity to identify unusual or potentially illicit transactions. Monitoring is performed on two levels:

• First Line: Engagement with trusted payment service providers that maintain AML controls, ensuring transactions are consistent with customer profiles and KYC data.
• Second Line: Internal AML team reviews and analyzes activity, applying due diligence and escalating as required.

Any unusual or suspicious activity identified through monitoring shall be escalated to the AML Officer for further review. Depending on the assessment, STARPH may file a report with the appropriate authorities in accordance with applicable law and may terminate the business relationship with the customer.

Source of Funds and Source of Wealth

For deposits that reach or exceed 5,000 USD, STARPH requires disclosure of Source of Funds and Source of Wealth. Acceptable SOW sources include employment income, business ownership, inheritance, investments, and family funds. Documentation may include bank statements, payroll records, corporate documentation, or independent third-party verification. If the origin or legitimacy of funds cannot be established, STARPH may place a hold on the relevant transactions and request additional documentation or suspend the account.

Risk-Based Classification and Enhanced Due Diligence

STARPH uses a risk-based approach to categorize customers by risk level and adjusts verification requirements accordingly. The three-tier model includes Low, Medium, and High risk classifications. Low risk customers follow standard verification procedures; Medium risk customers may face heightened checks and lower daily limits; High risk customers are subject to enhanced due diligence and may be restricted or blocked from certain activities until verified.

Record Keeping and Data Retention

STARPH maintains records of identification, verification, and transaction data for a minimum of ten years after the end of the customer relationship, or longer if required by applicable law. All records shall be stored securely with controlled access and appropriate safeguards against loss, alteration, or unauthorized disclosure.

Data Privacy and Access

Personal data collected under this policy is processed in accordance with STARPH privacy principles and applicable data protection laws. Customers may exercise rights to access, rectify, or erase their personal data in accordance with STARPH’s Privacy Policy. Data processing shall be limited to purposes of KYC, AML, and risk management and kept strictly confidential unless disclosure is required by law or regulatory authority.

Suspicious Activity Reporting and Cooperation with Authorities

STARPH will report suspicious transactions or knowledge or reasonable grounds to suspect money laundering or terrorist financing to the competent authorities in accordance with applicable law. STARPH shall cooperate with regulators and law enforcement, providing information reasonably requested to support investigations, while safeguarding customer privacy to the extent permitted by law.

Training and Awareness

STARPH provides ongoing AML and KYC training to all relevant staff. Training covers identification of typologies, escalation procedures, regulatory requirements, and the proper handling of sensitive information. Refresher training is conducted on an annual basis or as needed due to changes in risk factors or regulations.

Policy Review and Updates

This policy is reviewed at least annually or more frequently as required by changes in risk, products, or regulatory expectations. Updates shall be approved by senior management and communicated to staff and, where appropriate, customers, in accordance with regulatory obligations.