Scope and Definitions
This Know Your Customer (KYC) policy establishes Soul777's framework for customer identification, verification, risk assessment, ongoing monitoring, and information sharing to comply with applicable anti‑money laundering (AML) and counter‑terrorist financing (CTF) obligations. It applies to all individuals interacting with Soul777, including customers, employees, contractors, and agents acting on behalf of Soul777.
Governance and Risk‑Based Approach
Soul777 applies a risk‑based framework to identify, assess and mitigate money laundering and terrorist financing risks. Senior management directs the design, implementation, and operation of the KYC program and ensures appropriate resources and controls across all business lines.
- The Know Your Customer program comprises customer registration and acceptance, customer identification/verification, ongoing monitoring of activity, risk management, and the reporting of suspicious activity.
- Ongoing transaction monitoring is conducted to identify activity that does not conform with normal or expected patterns for each customer or account type.
Due Diligence Tiers
Soul777 uses a tiered due diligence framework based on risk, transaction type, and customer profile. The level of verification and monitoring increases with risk.
- SDD — Simplified Due Diligence is used for extremely low‑risk transactions with limited data collection and verification requirements.
- CDD — Customer Due Diligence is standard for most customers, including identity verification and basic data reconciliation with public sources where applicable.
- EDD — Enhanced Due Diligence is applied to high‑risk customers, large transactions, or complex structures, including enhanced verification, source of funds assessment, and intensified ongoing monitoring.
Customer Registration and Identity Verification
When a customer opens an account or engages in activity requiring KYC, Soul777 collects information to establish identity and location in accordance with applicable law. Verification steps include:
- Government‑issued photo identification (front and back where required) showing full name, date of birth, photograph, and document number.
- A selfie or live verification with the same individual holding the ID document, with biometric comparison where applicable.
- Proof of address, such as a bank statement or utility bill issued within the last three months, displaying the customer’s name and current address.
- Evidence that the name on the identification documents matches the name on account records and proofs of residence.
- The customer must be at least 18 years old and not reside in a restricted or prohibited jurisdiction to access Soul777 services, where permitted by law.
Thresholds and Triggers for KYC Completion
Soul777 reserves the right to require full KYC verification when activity exceeds predefined thresholds or when suspicious activity is detected. Triggers include:
- Aggregate lifetime deposits equal to or exceeding EUR 5,000 or equivalent in other currencies; or
- A withdrawal request or any transaction that Soul777 reasonably suspects may be linked to illicit activity; or
- Any activity flagged by monitoring systems or staff as suspicious; or
- Engagement with high‑risk jurisdictions or sanctioned entities, as determined by applicable law and licensing requirements.
Ongoing Monitoring and Review
Soul777 conducts ongoing monitoring of customer accounts and transactions to detect patterns that deviate from established profiles. Monitoring results may necessitate updated risk assessments, refresher verification, enhanced monitoring, or account restrictions, up to and including suspension where required by law or policy.
Data Handling, Disclosure, and third‑party Sharing
Soul777 maintains all customer information for the purposes of service delivery and compliance with applicable laws. Information may be used for investigations into fraudulent activity and Shared with appropriate parties as permitted by law, including:
- Investigative or regulatory authorities enforcing AML/CTF obligations;
- Service providers essential to delivering Soul777’s services;
- Regulatory bodies, financial institutions, and courts as required by law or licensing terms.
Suspicious Activity Reporting
Staff must file a suspicious activity report (SAR) when there are reasonable grounds to know or suspect that money laundering or related offenses are or have been committed. Staff are not obliged to actively seek indicators, but if awareness of suspicious activity arises during the course of normal duties, a SAR must be submitted. All relevant affiliates and partners must support and comply with SAR obligations under this policy.
Restricted Jurisdictions and Sanctions
Soul777 reserves the right to restrict access and services to users located in jurisdictions where provision of services would contravene applicable law, sanctions, or licensing conditions. This includes FATF‑identified high‑risk or restricted jurisdictions and any other jurisdictions deemed prohibited by Soul777 in accordance with regulatory requirements.
Compliance Responsibilities, Rights, and Contact
Soul777 may request any KYC documentation necessary to determine a user’s identity or location and may delay, restrict, or suspend services, payments, or withdrawals pending completion of verification. Customers must cooperate with KYC requests. Questions about this policy may be directed to Soul777 support through official customer channels.
Effective Date and Policy Updates
This policy is effective as of the date displayed in Soul777 disclosures and remains in effect until superseded. Material updates will be communicated to customers in accordance with applicable regulatory and licensing requirements.