AML & KYC Policy

We verify the identity of every account holder before their first withdrawal. An account holder verifies with any one of four documents — a 20-digit National ID (NIDA) number, a passport, a driving licence or a voter's card. We check the number against that document's format rule, enforce that the document is unique to a single account, and our compliance team reviews the photographic evidence together with a selfie. We capture: full name, date of birth, region, the document type and number, and photographic evidence.

Where we refuse an identity because the holder is under 18, because of a sanctions concern, or because the document is already used on another account, the account is frozen and a compliance officer decides what happens to its balance, case by case and with a recorded reason, as set out in section 3a of our Terms of Service.

Enhanced due diligence applies in these cases:

• A single deposit of TZS 1,000,000 or more, or deposits of TZS 5,000,000 or more within 30 days — the deposit is refused until our compliance team has accepted a source-of-funds declaration
• A compliance officer records a politically exposed person (PEP) or sanctions concern during an identity review or an enhanced due diligence review

A source-of-funds declaration may require supporting documentation (bank statement, salary slip, business registration). Where an account's identity has not yet been verified, the officer reviewing its declaration is shown that it is unverified.

Designated AML officers review flagged activity within 1 business day. SARs are filed with the Financial Intelligence Unit (FIU) of Tanzania within 7 days of identification, regardless of customer relationship. We do not tip off players that an SAR has been filed.

We do not run an automated screening feed against the UN, OFAC, EU or UK HMT sanctions lists. Sanctions and PEP exposure are assessed by a compliance officer as a checklist item during every identity review and every enhanced due diligence review, using the name, date of birth and document details collected under §1. Where an officer records a concern, the account may be suspended — which stops deposits, bets and withdrawals — and a suspicious-activity report is filed with the Financial Intelligence Unit where the law requires it. This policy states only the screening we actually perform; it will be re-versioned before any automated list screening is introduced.

Because identity is verified before an account's first withdrawal, the identity-review assessment takes place at that point.

CDD, transaction, and audit-trail records are retained for 7 years from account closure or transaction date, whichever is later. Logs are immutable, append-only, and signed.

All staff complete AML training annually with a refresher course every 6 months. The AML Officer reports directly to the Board. The Board reviews the AML risk register quarterly.

To raise an AML/KYC concern or ask about your records, contact our compliance team at msaada@50pick.tz.