AML Policy

1. Policy Statement

Vespera International Media Ltd., operator of GloomBet.com (the "Platform"), maintains Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") protocols designed to protect the integrity of the Platform ecosystem. GloomBet is a decentralized-style Web3 entertainment interface; the Platform is a software layer and we are not a licensed financial institution, bank, custodian, or broker. This Policy describes the compliance framework applied to Platform operations.

Our AML program is structured around internationally recognized standards and risk-based principles appropriate for digital asset entertainment platforms.

2. Regulatory Framework

Operators conduct periodic risk assessments to evaluate exposure to money laundering, terrorist financing, fraud, and sanctions-related threats. Assessments inform the calibration of verification thresholds, monitoring rules, and enhanced due diligence triggers applied across the Platform user base.

3. Know Your Customer (KYC)

Identity verification may be required prior to processing withdrawals above established thresholds, or at any time at our discretion. KYC documentation may include:

• Government-issued photo identification;
• Proof of residential address;
• Selfie or liveness verification;
• Source-of-funds declarations for high-volume accounts;
• Proof of ownership for cryptocurrency wallets used on the Platform.

Enhanced due diligence may apply to high-risk profiles, politically exposed persons, or accounts exhibiting unusual transaction patterns. Verification is processed through trusted third-party identity services.

4. Transaction Monitoring

We continuously monitor account activity, deposit and withdrawal patterns, wagering behavior, device fingerprints, and blockchain analytics to identify anomalies indicative of illicit activity. Automated rules and manual review workflows escalate flagged cases for further investigation.

Indicators include structuring below thresholds, rapid deposit-withdrawal cycles with minimal gameplay, sanctioned wallet exposure, and multi-account clustering linked to common devices or payment instruments.

5. Sanctions Screening

Users and associated wallet addresses are screened against applicable sanctions lists and blockchain intelligence blocklists. Matches trigger immediate review and may result in account restrictions, transaction holds, or permanent exclusion from the Platform.

6. Suspicious Activity Reporting

Where Operators form a reasonable suspicion that funds are derived from criminal activity or relate to terrorist financing, reports may be filed with the appropriate financial intelligence unit or competent authority as required by applicable law. Users will not be notified of such reporting where disclosure is prohibited.

7. Record Retention

Compliance records, verification documents, and transaction histories are maintained for periods consistent with AML industry standards for digital asset platforms. Records may be retained in electronic form across distributed infrastructure.

8. Prohibited Activity

Users must not employ the Platform to launder proceeds of crime, evade sanctions, finance terrorism, or transfer value on behalf of unauthorized third parties. Violations may result in immediate account termination and balance forfeiture where permitted by applicable law.

9. User Obligations

By using the Platform, you represent that all deposited funds originate from lawful sources and that you are not subject to sanctions prohibiting Platform access. You are solely responsible for compliance with AML/CTF obligations applicable in your jurisdiction. The Platform is provided "AS IS"; Operators make no representation regarding the legality of Platform use in any territory.

10. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, OPERATORS SHALL NOT BE LIABLE FOR ANY LOSS, PENALTY, OR INVESTIGATION ARISING FROM YOUR USE OF THE PLATFORM OR YOUR FAILURE TO COMPLY WITH APPLICABLE AML/CTF LAWS IN YOUR JURISDICTION.

11. Contact

Compliance inquiries may be directed through Live Support on the Platform.