Purpose and Scope

Frogger Jump maintains an Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy to prevent the platform from being used for money laundering or the financing of illicit activity. The policy governs all Frogger Jump activities, including customer onboarding, payments, betting transactions, withdrawals, and interactions with third‑party service providers. It applies to all jurisdictions in which Frogger Jump operates and to all user types, including players, agents, and affiliates.

Definitions

  • AML/CFT: Anti-money laundering and counter-terrorist financing obligations under applicable law.
  • KYC/CIP: Know Your Customer and Customer Identification Program procedures used to verify identity and assess risk.
  • STR: Suspicious Transaction Report submitted to the competent authority when indicators of AML risk are identified.
  • Sanctions and Geo-blocking: Screening against official sanctions lists and restricting access from prohibited jurisdictions.
  • EWRA: Enterprise-Wide Risk Assessment to identify and measure AML risk across products, processes, and geographies.
  • Personal data and privacy: Information processed by Frogger Jump in accordance with applicable privacy laws and the Frogger Jump Privacy Policy.

Corporate Governance and EWRA

Senior management, including the designated AML/Compliance Officer, is responsible for the implementation and ongoing effectiveness of the AML/CFT program. The policy requires an annual EWRA to identify material AML risks across products, payment methods, geographies, and customer segments, and to document mitigating controls and residual risk levels.

KYC/CIP Program

Onboarding requires verification of identity and control factors before any payout is processed. The program collects and reviews information sufficient to establish identity, assess source of funds, and determine the customer’s risk profile. Ongoing monitoring is conducted for changes in risk, with enhanced due diligence applied to higher‑risk customers or transactions.

Sanctions Compliance and Geo-Blocking

Frogger Jump screens customers and beneficiaries against applicable sanctions lists and blocks access for listed individuals or entities. Geo-blocking and controlled access measures are applied where required by law or heightened risk evaluations. Screening data is refreshed on a defined cadence and in response to regulatory updates.

Transaction Monitoring

Automated monitoring systems detect atypical or suspicious patterns, including unusual deposit or withdrawal activity, rapid velocity, or inconsistent source of funds. Alerts are prioritized by risk level and reviewed by the AML/compliance team within defined timeframes. High‑risk cases may trigger additional verification or manual review.

Suspicious Transaction Reporting (STR)

Staff must report suspicious activity through the internal escalation workflow. The compliance function drafts STRs for submission to the competent authorities in accordance with legal deadlines. Supporting documentation is retained for the applicable retention period and is accessible for regulatory review.

Record Keeping and Data Storage

All KYC records, identity documents, transaction histories, and AML investigations are retained for a minimum of eight (8) years. Records are stored securely with access restrictions, and data handling complies with applicable privacy and data protection laws. Retention periods apply notwithstanding account status or service level changes.

Vendor Management

Frogger Jump conducts due diligence on third‑party vendors that support AML controls, including payment processors and identity verification providers. Contracts include AML and data‑protection obligations, with ongoing monitoring and the right to terminate for AML‑related noncompliance or material risk changes.

Training and Awareness

All employees undergo AML/CFT training upon hire and receive periodic refreshers. Training covers KYC procedures, transaction monitoring, STR processes, sanctions screening, and whistleblowing channels. Completion records are maintained by the Compliance function.

Independent Audit and Testing

The AML program is subject to independent review and testing at least annually, or more frequently based on risk. Findings are reported to senior management and the board, with timely remediation plans and verification of effectiveness.

Whistleblowing Channels

Frogger Jump maintains confidential channels for reporting concerns about AML/CFT compliance. Reports are handled separately from normal operations, with protections against retaliation and clear escalation pathways to the Compliance function.

Key Performance Indicators (KPIs)

Key metrics include onboarding verification rate, time to complete KYC checks, number of STRs filed and resolved, average time to resolve AML investigations, and the proportion of high‑risk customers requiring enhanced due diligence.

Business Continuity Plan (BCP)

The AML controls are incorporated into the Frogger Jump BCP. The plan ensures continuity of identity verification, transaction monitoring, and reporting capabilities during disruptions, with data backups, alternate processing arrangements, and recovery time objectives aligned to regulatory expectations.

Policy Updates

The AML/CFT Policy is reviewed at least annually and amended as required to reflect regulatory changes, industry guidance, and internal risk assessments. Any material amendments are communicated to staff and relevant stakeholders in a timely manner.

Data Privacy and Security Interface

Frogger Jump processes personal data for AML/CFT purposes in accordance with applicable data protection laws and the Frogger Jump Privacy Policy. Data subjects retain rights under applicable law, including access, correction, and deletion requests, subject to regulatory and contractual constraints. All data processing supports secure, auditable, and limited access to information necessary for AML controls.

Enforcement and Contact

Non‑compliance with this policy may result in account restrictions, suspension, termination, or legal action as permitted by law. For questions or disclosures related to AML/CFT, contact the Frogger Jump Compliance function through approved internal channels.