Anti-Money Laundering Policy

Introduction

This Anti-Money Laundering Policy (the “Policy”) governs the activities of Runa Casino (the “Company”) in combating money laundering, terrorist financing, and other illegal or fraudulent activities. It explains the measures taken by the Company to comply with current anti-money laundering legislation and how these measures impact users of runacasino.io (the “Website”).

The Company reserves the right to amend this Policy at any time. Continued use of the Website following such changes constitutes acceptance of the revised Policy.

1. Implementation of this Policy

The Company applies this Anti-Money Laundering program in the following ways:

• Verification of customers (“Users”) of the Website.
• Use of FATF-defined risk categories to evaluate whether a User presents a risk of money laundering or terrorist financing.
• Continuous monitoring of all transactions conducted by users.
• Employee training to maintain up-to-date knowledge of AML practices.

2. Risk Categories

The Company uses the FATF risk-based approach to determine whether Users present potential AML risks.

2.1 Country / Geographic Risk

The Company reviews each User’s jurisdiction against the European Commission’s list of “high-risk third countries” and FATF’s list of “high-risk and other monitored jurisdictions.” Additional internal assessments include:

• Legal environment
• Political environment
• Economic structure
• Cultural and civil context
• Sources and concentration of criminal activity

2.2 User Risk

The Company monitors user activity for factors that may indicate high-risk behavior, including:

• Excessive or abnormal spending
• Suspicious account activity, such as multiple devices or shared IP addresses
• Designation as a Politically Exposed Person (PEP)

2.3 Transaction Risk

• No anonymous payment instruments are accepted.
• No transfers between user accounts are allowed.
• Cash transactions are not accepted.
• Only reputable electronic wallets from approved jurisdictions are permitted.
• Deposits from instruments not owned by the User are not accepted.

3. Verification

Verification may be required when:

• Total transactions exceed EUR/USD 10,000;
• The User falls into one or more FATF risk categories;
• Suspicious activity is detected;
• Other cases where verification is deemed necessary by the Company.

Documents required for verification:

• Photo ID
• Photo of payment card used for deposits (with CVV and middle digits covered)
• Selfie holding the ID and handwritten note with account email and date
• If applicable, bank statement or proof of address (utility bill, tax bill, etc.)
• Additional documents if required
• Video verification may be requested

3.1 Additional Verification

• Applies to Politically Exposed Persons (PEPs)
• Applies to users from FATF or EU high-risk jurisdictions
• May be required by law or at the request of authorities

Additional verification may include proof of income or source of funds. Refusal to provide verification or suspicion of illegal activity may result in account suspension and reporting to authorities.

4. Record Keeping

The Company retains verification and transaction data for a period of five (5) years in compliance with applicable laws. Please refer to the Privacy Policy for details on personal data storage.

5. Activity Monitoring

The Company continuously monitors all transactions to ensure they meet AML requirements, including matching user and account names and verifying payment instruments belong to the same person.

Stages of money laundering identified by FATF include:

• Placement – converting funds into financial instruments or purchases.
• Layering – transferring or converting funds to obscure their source.
• Integration – reintroducing laundered funds into the economy as legitimate assets.

5.1 Suspicious Activity Prevention

Deposits and withdrawals are screened for indicators such as use of multiple cards, mismatched geolocation data, refusal to verify instruments, or matching device IDs across accounts.

6. Staff Training

The Company provides ongoing AML training for staff responsible for financial and verification operations, ensuring awareness of FATF guidance, legislative updates, and best industry practices.

7. References

• The FATF Forty Recommendations and Special Recommendations on Terrorism Financing
• FATF Risk-Based Approach Guidance for Casinos
• EU Directive 2015/849 on AML/CTF
• Commission Delegated Regulation (EU) 2016/1675 identifying high-risk third countries
• Law No. 8204 on Narcotics and the Financing of Terrorism
• FATF list of High-Risk and Other Monitored Jurisdictions: fatf-gafi.org