Kyc

Know Your Customer (KYC) Policy

33bd adheres to Know Your Customer principles to prevent financial crime and money laundering through customer identification and due diligence. The Company may request documentation it deems necessary to determine the identity and location of a user and may restrict services, payments or withdrawals until identity is sufficiently established or for any reason in the Companys sole discretion consistent with applicable law.

Scope and Application

This policy applies to all users accessing 33bd services, including onboarding, deposits, withdrawals and any transactions conducted on the platform. 33bd applies a risk based approach to due diligence for all clients and performs ongoing monitoring of all transactions in line with legal obligations.

Regulatory Framework

33bd operates under the applicable anti money laundering and countering the financing of terrorism laws and guidance in the jurisdiction of operation. The controls are aligned with national and international standards including FATF recommendations and are designed to comply with the requirements of the competent supervisory authority. The Company maintains policies for customer due diligence, record keeping and internal reporting of suspicious activity as required by law.

Risk Based Approach and Due Diligence

The Company employs a risk based framework to identify, assess and mitigate financial crime risks. Risk categories include:

  • Customer risk based on identity, source of funds and expected activity
  • Product risk related to the services used
  • Geographical risk associated with customer residence or business operations
  • Channel risk associated with the method of onboarding or transaction submission

Initial due diligence is conducted prior to establishing a business relationship. Ongoing due diligence is performed at defined intervals and whenever there is a material change in risk. Enhanced due diligence is applied for high risk scenarios, including large or complex transactions or known adverse information.

KYC Triggers and Onboarding Flow

KYC verification is triggered on onboarding and may be re triggered in response to changes in risk or upon request by Compliance. The following thresholds apply:

  • Aggregate lifetime deposits exceeding EUR 5 000 require full KYC verification
  • Any withdrawal request from a newly created or materially at risk account triggers full KYC verification
  • Suspicious activity or transactions trigger mandatory KYC verification regardless of thresholds

On completion of verification, the account is either approved as verified or remains pending pending additional information. If verification is unsuccessful, the reason is documented and a compliance ticket is opened. The user is informed of the outcome and provided with the ticket number and the reason. The user may re submit documents or supply additional information as part of remediation.

Documentation and Verification Requirements

Users must provide the following to complete KYC verification:

  • Government issued photo identification. The document should be valid and may require front and back copies depending on the document type.
  • A selfie of the user holding the ID document.
  • Proof of residence from a bank statement or utility bill issued within the last three months showing the full name and current address.
  • Information must be accurate and consistent across documents. The full name must match the name on the proof of ID. The country of residence must be verifiable and not in a restricted list.
  • Document validity checks: the ID must not be expired in the next three months at the time of submission; date of issue must be within the last three months; the holder must be at least 18 years old.

Restricted Jurisdictions

Onboarding and ongoing relationships are not available to users located in or resident in jurisdictions where participation is prohibited by applicable law or licensing requirements. This includes, but is not limited to, jurisdictions such as Austria, France and its territories, Germany, Netherlands and its territories, Spain, United Kingdom and its territories, United States and its territories, FATF blacklisted jurisdictions, and any other jurisdiction prohibited by the Companys licensing authority.

Ongoing Monitoring and Re Verification

The Company maintains ongoing monitoring of customer activity and performs periodic reviews to ensure adherence to risk profiles. Re verification may be required when risk factors change, when information needs to be updated, or upon regulatory request. An audit trail of verification steps, supporting documents and decisions is maintained for compliance purposes.

Data Retention and Privacy

KYC records are retained for a minimum of five years after the termination of the business relationship or as required by applicable law. Records are stored securely with access restricted to authorized personnel. Personal data processed for KYC purposes is handled in accordance with the Companys data protection and privacy obligations.

Handling of Unsuccessful Verifications

When verification is unsuccessful the reason is documented and a Compliance ticket is opened. The user is informed of the outcome, the ticket number and the reason. The user may re submit documentation or provide additional information as part of the remediation process. If needed, the matter may be escalated to Compliance for further action.

Contact and Inquiries

For questions related to KYC processing, users may contact the dedicated KYC support channel at 33bd provided contact address.

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