反洗钱与 KYC 政策

反洗钱与客户身分验证（KYC）政策

Twocent Limited ("Tenka", "we") is committed to preventing the platform from being used to launder money, finance terrorism, or evade sanctions. This policy sets out the controls we apply. It forms part of our Terms of Service; by using the Site you agree to cooperate with the checks described here.

1. Scope and legal basis

This policy applies to every player, every deposit and withdrawal, and every member of staff. It is designed to meet the anti-money-laundering (AML) and counter-terrorist-financing (CTF) requirements applicable to us in the Autonomous Island of Anjouan, Union of Comoros under licence ALSI-202410011-FI1, and the recommendations of the Financial Action Task Force (FATF) as they apply to virtual-asset businesses. Because Tenka accepts only cryptocurrency, the policy includes controls specific to blockchain transactions.

2. Risk-based approach

We do not treat every player the same. Each account is assigned a risk rating that we review continuously, based on factors such as:

• the volume, frequency and pattern of deposits, bets and withdrawals;
• the coins and networks used, and what our blockchain screening tells us about the source and destination addresses;
• country of residence and IP location, and whether they match;
• results of sanctions and politically-exposed-person (PEP) screening;
• behaviour that is inconsistent with gambling, such as depositing and withdrawing with little or no play.

Higher risk means more verification, closer monitoring, and lower thresholds before we ask questions.

3. Customer due diligence (KYC)

When you register we collect your email address and your confirmation that you are 21 or older and that gambling is legal where you live. Full identity verification is required:

• before a withdrawal is approved, at the latest once your total deposits or withdrawals reach 2,000 USDT (or the equivalent in another coin) in any rolling 30-day period, or cumulatively;
• whenever a risk trigger described in this policy applies, regardless of amount;
• at any other time we or our licensing authority consider it necessary.

Standard verification consists of:

1. Identity — a clear photo of a valid government-issued ID (passport, national ID card or driving licence) and, where requested, a selfie or short liveness check. The name and date of birth must match your account and confirm you are at least 21.
2. Address — a utility bill, bank statement or official letter issued within the last three months, showing your name and residential address.
3. Wallet ownership — where requested, evidence that a withdrawal address belongs to you, such as a signed message or a screenshot from your wallet.

Until verification is complete, withdrawals are held. If documents are not supplied within a reasonable time we may suspend or close the account, and we will return verified deposits to their originating wallet where the law allows.

4. Enhanced due diligence and source of funds

We apply enhanced due diligence when a player is rated high risk, is a PEP or a close associate of one, deposits unusually large amounts relative to their history, or where blockchain screening shows exposure to high-risk sources. Enhanced due diligence can include:

• evidence of source of funds for the specific deposits — for example exchange purchase records, payslips, business income, or a sale agreement;
• evidence of source of wealth — an explanation, supported by documents, of how the overall wealth was built up;
• senior-management approval before the business relationship continues;
• more frequent review and lower monitoring thresholds.

5. Sanctions and PEP screening

Player names and, where available, dates of birth and nationalities are screened at onboarding and periodically thereafter against international sanctions lists (including UN, EU, UK and US OFAC lists) and PEP databases. Deposit and withdrawal addresses are screened against lists of sanctioned and criminal wallets. A confirmed sanctions match results in the immediate freezing of the account and funds and a report to the competent authority; we will not knowingly do business with sanctioned persons or with residents of comprehensively sanctioned territories.

6. Ongoing monitoring

Transactions are monitored automatically and by our compliance staff. Examples of patterns that trigger review:

• deposits followed by a withdrawal request with minimal wagering ("pass-through" activity);
• several deposits just below a threshold in a short period (structuring);
• deposits from, or withdrawal requests to, addresses linked to mixers, darknet markets, ransomware, hacks, sanctioned entities, or gambling sites that do not perform KYC;
• use of many different wallets, coins or networks with no plausible reason;
• the same device, IP address or documents appearing on more than one account;
• rapid changes of withdrawal address, or requests to withdraw to a third party.

7. Crypto-specific controls

• Deposits and withdrawals must go to and from wallets you own and control. Withdrawals to third parties are not permitted.
• Every deposit address is screened with blockchain-analytics tooling before funds are credited or, if screening is delayed, before withdrawal. Deposits assessed as high risk may be frozen pending investigation and, where the law requires, reported rather than returned.
• We may require withdrawals to be made in the same coin as the deposit and only after the deposit has been wagered, so the Site cannot be used as an exchange.
• We do not accept privacy-coin deposits where the source cannot be traced, and we may remove any coin from the list at any time.

8. Record keeping

We keep identity documents, verification results, risk assessments, transaction records (including on-chain hashes), and the notes of any investigation for at least five years after the account is closed or the transaction took place, whichever is later, and longer if an investigation or legal proceeding is open. Records are stored securely as described in our Privacy Policy and are available to our licensing authority on request.

9. Reporting

Where we know, suspect, or have reasonable grounds to suspect that funds are the proceeds of crime or are linked to terrorist financing, our compliance officer files a suspicious-activity report with the competent financial-intelligence unit. The law prohibits us from telling a player that a report has been made ("tipping off"), so we may decline to explain why a withdrawal is delayed or an account is restricted. We cooperate fully with lawful requests from regulators and law-enforcement agencies.

10. Refusal, suspension and freezing

We may refuse a deposit, hold or reject a withdrawal, suspend an account, or freeze funds where verification is incomplete, where a risk trigger is unresolved, where we suspect a breach of this policy or the law, or where an authority instructs us to. Where funds are frozen because of a legal obligation they will be released only when that obligation permits.

11. Governance and training

A designated compliance officer is responsible for this policy, for approving high-risk relationships, and for reporting. All staff with access to player data or payments receive AML training at onboarding and at least annually. This policy is reviewed at least once a year and whenever the law, our licence conditions, or our risk assessment change.

12. Contact

Questions about verification, or to submit documents securely, use the support page or email [email protected]. Never send documents through the public chat.