Aml

Introduction and Purpose

Rocketpot maintains this Anti Money Laundering (AML) policy to prevent money laundering and the financing of terrorism within all activities on the platform. The policy defines governance, customer due diligence, risk-based controls, ongoing monitoring, and reporting obligations applicable to all users, employees, and associated service providers.

Governance and Compliance Oversight

Senior management holds ultimate responsibility for the AML program. The policy establishes an Anti Money Laundering Compliance Officer (AMLCO) who enforces the policy, coordinates training, and oversees ongoing compliance. The AML framework requires adherence to applicable laws and enables reporting to competent authorities where warranted by law. The AMLCO operates with independence and authority to request information and initiate appropriate action.

Customer Identification and Verification

Rocketpot employs a three stage verification process for onboarding and for withdrawal eligibility. Stage one collects essential personal data: given name, family name, date of birth, country of usual residence, and full address. Stage two requires submission of official identification documents issued by a competent authority; documents must be legible and the ID must be presented in a manner that allows all required details to be read. Where feasible, electronic verification against trusted data sources is performed; if electronic verification is unavailable or unsuccessful, a manual verification process may be used with supporting documentation. Stage three addresses the source of funds or wealth for transactions exceeding defined thresholds and requires disclosure of the funds’ provenance supported by documentation. Pending completion of stages two or three, withdrawal or deposit activity may be temporarily restricted.

Risk-Based Verification and Regional Considerations

Rocketpot applies a risk-based approach to customer due diligence. Customers are categorized by regional risk into low, medium, and high bands. Region one (low risk) permits standard verification; region two (medium risk) requires enhanced verification with adjusted thresholds for deposits and withdrawals; region three (high risk) may be subject to enhanced scrutiny or be restricted in accordance with regulatory requirements. The risk profile is reviewed at least annually and when a material change in the customer’s circumstances occurs.

Source of Funds and Source of Wealth

For transactions exceeding defined thresholds, Rocketpot requires substantiation of the lawful source of funds and, where applicable, the source of wealth. Acceptable sources include employment income, business ownership, inheritance, investment proceeds, and other credible means. Where documentation does not establish provenance, Rocketpot may request additional information and may suspend activity until resolution is achieved. Documentation may include bank statements, payslips, tax documents, or other corroborating materials.

Ongoing Monitoring and Transaction Surveillance

Ongoing transaction monitoring is maintained to detect unusual or suspicious activity. The monitoring framework operates on two levels: (1) First Line of Control — Rocketpot partners with trusted payment service providers that maintain compliant AML controls; (2) Second Line of Control — an internal AML function reviews activity for consistency with the customer profile and applies due diligence where warranted. The system flags requests for unusual transactions, inconsistent payment methods, or anomalous patterns. All flagged activity is escalated to the AMLCO for further review and, where necessary, additional documentation requests or enhanced due diligence.

Record Keeping

Rocketpot shall retain all customer identification, verification data, and transaction records for a minimum of ten years after the termination of the business relationship or completion of the relevant transactions. Records are stored securely in encrypted form and are accessible to competent authorities in accordance with applicable law and regulatory requirements.

Suspicious Activity Reporting and Prohibition on Tipping Off

Any employee who knows or suspects money laundering or the financing of terrorism must report in accordance with internal procedures and applicable law to the designated AML officer. Disclosure or tipping off that a report has been made is strictly prohibited and may carry legal penalties. Reports are treated confidentially to preserve investigative integrity and do not disclose to the customer the existence of an investigation unless legally required.

Training and Awareness

Rocketpot provides ongoing AML training for relevant staff, focusing on customer due diligence, enhanced due diligence for higher risk scenarios, escalation procedures, and the handling of suspicious activity reports. Training content is reviewed regularly to reflect regulatory developments and internal controls.

High Risk Jurisdictions and Sanctions

Rocketpot applies enhanced controls to customers located in or connected with high risk jurisdictions as identified by FATF and other competent authorities. Where required by law or regulation, Rocketpot will apply enhanced due diligence or refuse service to customers from high risk jurisdictions. The policy is updated to reflect changes in regulatory designations.

Employee Vetting and Internal Controls

New employees undergo appropriate vetting including identity verification and reference checks. Access to sensitive data and operational infrastructure is controlled through a combination of physical and logical security measures. An internal governance structure, including an AML function and compliance oversight, ensures ongoing risk management and policy adherence.