Effective Date: June 1, 2025
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros
IOGr B.V. (referred to as the “Company”, “we”, “our”, or “us”) operates the website chicken-road-official.ca, together with its related subdomains, systems, and services (collectively, the “Website”).
This Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy describes the measures we apply to identify, verify, and continuously assess our business partners in order to comply with applicable regulatory obligations and to prevent the misuse of our services for money laundering, terrorist financing, fraud, or other unlawful activities.
1. Objective and Applicability
The purpose of this Policy is to establish a clear framework for KYC and AML controls aimed at reducing financial crime risks.
This Policy applies to all B2B counterparties, including but not limited to gaming operators, distributors, resellers, platform providers, system integrators, and other corporate entities that enter into a commercial relationship with the Company.
2. Risk-Based Compliance Framework
We follow a risk-based approach when onboarding and monitoring clients. Each business relationship is evaluated based on a combination of risk factors, which may include:
- Country of incorporation and operational presence
- Ownership structure and control, including Ultimate Beneficial Owners (“UBOs”) and nominee arrangements
- Nature of the business, products offered, target markets, and distribution channels
- Licensing status, regulatory background, and compliance history
- Publicly available information, including adverse media
- Transaction patterns and behavioral indicators, where applicable
Based on this assessment, clients are categorized as requiring either Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD). Risk classifications are reviewed at least once per year and immediately upon any material change, such as ownership updates, corporate restructuring, jurisdictional shifts, or licensing amendments.
3. Client Due Diligence Standards
3.1 Customer Due Diligence (CDD)
As part of standard onboarding, clients are required to submit accurate and up-to-date documentation (generally issued within the last three months, where relevant), including:
- Certificate of Incorporation or official extract from a recognized trade register
- Articles and/or Memorandum of Association or equivalent constitutional documents
- Proof of registered business address (for example, a utility bill or bank statement)
- Corporate ownership chart clearly identifying shareholders and Ultimate Beneficial Owners
- Identification documents for directors and UBOs holding more than 25% ownership, including:
- Valid government-issued photo identification (passport or national ID)
- Proof of residential address (utility bill, bank statement, or equivalent)
3.2 Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied where increased risk factors are identified, including but not limited to:
- Links to jurisdictions classified as high-risk or non-cooperative by the FATF
- Complex, opaque, or layered ownership structures
- Involvement of Politically Exposed Persons (PEPs), their close associates, or family members
- Prior regulatory enforcement actions, sanctions exposure, or significant negative media coverage
EDD measures may involve additional verification steps, such as:
- Evidence of Source of Funds (SoF) and/or Source of Wealth (SoW) for the entity and its UBOs
- Independent compliance reports or third-party AML audit findings
- Verification of relevant gaming, operating, or regulatory licenses
- Expanded sanctions, reputational, and background screening
4. Ongoing Monitoring and Reviews
All business relationships are subject to continuous monitoring. Periodic reviews are conducted at least annually and on an ad hoc basis following triggering events such as changes in ownership, management, jurisdiction, or regulatory status.
If unusual, inconsistent, or potentially suspicious activity is identified, the Company may request additional information, impose restrictions, or temporarily suspend services while an internal review is carried out. Clients are required to promptly inform us of any developments that may impact their risk profile.
5. Sanctions and PEP Screening
The Company screens directors, shareholders, and UBOs against recognized global sanctions and PEP databases, including but not limited to those maintained by the United Nations, European Union, and OFAC, as well as reputable commercial screening providers.
Confirmed matches or material adverse findings may result in enhanced scrutiny, refusal of onboarding, suspension of services, or reporting to competent authorities, where legally required.
6. Record Retention
All KYC and AML records, whether maintained electronically or in physical form, are retained for a minimum period of six (6) years following the termination of the business relationship, in accordance with applicable AML regulations in the Autonomous Island of Anjouan.
7. Prohibited and Restricted Jurisdictions
The Company does not establish or maintain business relationships with entities that are:
- Registered, owned, or controlled by persons from FATF high-risk or non-cooperative jurisdictions
- Located in or connected to countries subject to UN, EU, or OFAC sanctions
- Operating within the Union of the Comoros for white-label services targeting that jurisdiction
- Otherwise restricted by directives issued by the Anjouan Offshore Financial Authority
8. Non-Compliance Consequences
Failure to provide complete, accurate, or timely KYC/AML information may lead to one or more of the following actions:
- Refusal to proceed with onboarding
- Temporary suspension of services
- Termination of the contractual relationship
- Disclosure or reporting to regulatory or law enforcement authorities, where required by law
9. Policy Updates and Amendments
This Policy may be revised periodically to reflect changes in legal requirements, regulatory expectations, or internal procedures. Where practicable, material updates will be communicated to affected clients in advance. The most current version of this Policy will always be available on the Website and will take effect upon publication unless stated otherwise.