1w KYC & AML Policy

KYC, or Know Your Customer, refers to the process of verifying the identity of an individual who registers and uses an online platform. AML, or Anti-Money Laundering, encompasses a broader set of controls designed to detect and prevent the use of gambling services for laundering illegally obtained funds.

Together, these frameworks serve several important functions:

• Confirming that account holders are who they claim to be;
• Preventing unauthorised access and account fraud;
• Ensuring that financial transactions on the platform are legitimate;
• Supporting transparency in the movement of funds;
• Meeting the obligations imposed by New Zealand's regulatory environment, including standards aligned with the Financial Intelligence Unit (FIU) and the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).

For users, KYC and AML measures provide assurance that their personal data, funds, and account activity are protected within a structured and monitored environment. These procedures are standard practice across licensed gambling operators and reflect a commitment to responsible financial operations.

Identity verification may be requested at various points during an account holder’s use of the platform. The circumstances that typically prompt a verification request include:

• Registration and account activation: confirming the identity of a new user before full platform access is granted;
• Age confirmation: ensuring that the account holder meets the minimum legal age requirement for online gambling in New Zealand, which is 20 years of age;
• Withdrawal requests: verifying account ownership before releasing funds to a payment method;
• Payment method verification: confirming that the payment instrument used belongs to the registered account holder;
• Fraud prevention: identifying and preventing the misuse of accounts through false or stolen credentials;
• Regulatory compliance: fulfilling the obligations placed on licensed operators to confirm user identities and monitor financial activity.

Verification protects both the platform and its users. Account holders benefit from the assurance that their funds and personal information are accessible only to them. The platform, in turn, fulfils its legal duty to prevent financial abuse and maintain the integrity of its operations.

During the document submission process, 1w may request a range of materials to confirm an account holder’s identity and the legitimacy of their financial activity. The specific documents required will depend on the nature of the verification check.

Identity Verification

Documents commonly accepted for ID verification include:

• A valid government-issued passport;
• A national identity card;
• A current driver’s licence.

The document submitted must clearly display the account holder’s full name, date of birth, and photograph.

Proof of Address

To confirm a residential address, the following types of documents may be accepted:

• A recent utility bill (no older than three months);
• A bank or financial institution statement;
• An official government correspondence displaying the account holder’s name and address.

Payment Method Verification

Confirmation that a payment method belongs to the registered user may require:

• A bank statement showing the account holder’s name;
• A screenshot or image of the payment card used, with sensitive digits appropriately obscured;
• Documentation relevant to e-wallet accounts or other digital payment instruments.

Additional Supporting Documents

In certain circumstances, additional materials may be requested, including documentation related to the source of funds or further identity confirmation. All requests for supplementary documents will be communicated directly to the account holder.

The verification process on 1w is structured to be clear and systematic. The following outlines the general stages an account holder may experience:

1. Notification of verification requirement: The account holder is informed that verification is required, either at registration or at a later stage based on account activity or a withdrawal request.
2. Document submission: The account holder uploads the requested documents through the designated area of their account or via a supported submission method.
3. Review and assessment: The submitted documents are reviewed by the compliance team to confirm their validity, legibility, and consistency with the account details on record.
4. Outcome communication: The account holder is notified of the outcome. If the documents are accepted, the relevant restriction is lifted. If further information is required, a follow-up request will be issued.
5. Follow-up requests: In cases where submitted documents are insufficient or additional verification is required, the account holder will be contacted with specific instructions.

Processing times may vary depending on the volume of verification requests and the completeness of the documents provided. Account holders are encouraged to submit clear, legible copies of all required materials to avoid delays. Accounts may remain restricted during the verification period until all required checks are satisfactorily completed.

1w applies a range of anti-money laundering measures to maintain a secure and compliant platform environment. These controls are embedded across the platform’s operations and are reviewed in line with evolving regulatory standards.

Key AML measures implemented by the platform include:

• Transaction monitoring: All financial activity on the platform is subject to systematic monitoring to identify patterns or behaviours that may indicate irregularities;
• Risk-based account assessments: Account holders may be assigned a risk profile based on their activity, deposit and withdrawal history, and verification status;
• Unusual activity detection: Automated systems and manual review processes are in place to flag transactions or account behaviours that fall outside expected patterns;
• Enhanced due diligence: In higher-risk cases, additional verification steps may be applied, including requests for source of funds documentation;
• Internal reporting procedures: The platform maintains internal processes for escalating and reporting suspicious activity in accordance with New Zealand’s AML/CFT Act obligations;
• Staff training and oversight: Personnel responsible for compliance are trained to recognise and respond to potential financial misconduct.

These measures are not directed at any individual user and are applied consistently across the platform as part of its compliance obligations.

Financial transactions processed through the platform are subject to ongoing monitoring as part of the platform’s AML framework. This monitoring serves to identify activity that may be inconsistent with a user’s account profile or that may indicate potential misuse.

Automated Monitoring Systems

The platform uses automated systems to track and assess transaction activity. These systems are configured to detect:

• Transactions that fall outside the typical behaviour patterns of an account holder;
• Large or frequent deposits or withdrawals that may warrant further review;
• Rapid cycling of funds through deposits and withdrawals with minimal gambling activity;
• Use of multiple payment methods in a manner that may suggest an attempt to obscure the origin of funds.

Manual Review Processes

In addition to automated tools, compliance personnel may conduct manual reviews of accounts and transaction histories. Manual reviews may be initiated by flagged alerts from automated systems or by broader account monitoring observations.

Risk-Based Approach

The platform applies a risk-based approach to transaction monitoring. Account holders may be assessed on a spectrum of risk levels, with higher-risk accounts subject to more detailed scrutiny. Factors that may influence a risk assessment include the account holder’s verification status, transaction history, and the geographical context of their activity.

Transaction monitoring is a standard regulatory requirement for licensed gambling operators and is applied to support user safety and platform integrity.

In certain circumstances, account holders may be asked to provide information or documentation regarding the origin of the funds they deposit and use on the platform. This process, commonly referred to as source of funds verification, is a component of responsible financial operations and AML compliance.

Circumstances That May Prompt This Request

Source of funds verification may be requested in the following situations:

• When an account holder's deposit activity is notably high relative to their established profile;
• When transaction patterns suggest an unusual accumulation or movement of funds;
• When enhanced due diligence is required as part of a risk-based assessment;
• When regulatory obligations require confirmation of the legitimate origin of funds.

Types of Documentation That May Be Accepted

Account holders may be asked to provide materials such as:

• Recent payslips or employment contracts;
• Bank statements demonstrating regular income;
• Documentation confirming a business income, investment return, or other identified source;
• Any other documentation that reasonably substantiates the origin of the funds in question.

Account holders are advised to respond to source of funds requests in a timely manner. Failure to provide satisfactory documentation may result in account restrictions until the matter is resolved. All information submitted is treated with strict confidentiality and handled in accordance with the platform's data protection obligations.

Certain activities are strictly prohibited under the KYC and AML Policy of 1w. Account holders found to have engaged in restricted activities may face account suspension, permanent closure, or reporting to relevant authorities in accordance with legal obligations.

Prohibited activities include:

• Identity fraud: Submitting false, altered, or forged identity documents during the verification process;
• Providing inaccurate information: Supplying incorrect personal details at registration or during account reviews;
• Third-party account use: Allowing another individual to access, operate, or transact on an account registered to a different person;
• Third-party payment use: Depositing or withdrawing funds using a payment method that does not belong to the registered account holder;
• Structuring transactions: Deliberately breaking up deposits or withdrawals into smaller amounts in an attempt to avoid detection by monitoring systems;
• Circumventing verification: Attempting to bypass or delay identity or source of funds checks through any means;
• Use of proceeds from criminal activity: Depositing or transacting with funds derived from illegal sources;
• Suspicious financial conduct: Engaging in patterns of financial activity that are inconsistent with legitimate gambling behaviour and may indicate an attempt to exploit the platform.

The platform reserves the right to take appropriate action, including withholding funds pending investigation, where there is reasonable suspicion that any of the above activities have occurred.

Accounts on the platform may be subject to periodic reviews as part of ongoing compliance obligations. These reviews are not necessarily indicative of any wrongdoing and may be conducted as part of routine due diligence procedures.

Situations That May Trigger an Account Review

A compliance check or account review may be initiated in the following circumstances:

• A significant change in transaction volume or frequency;
• The expiry or invalidation of previously submitted verification documents;
• Discrepancies identified between account information and submitted documents;
• Alerts generated by transaction monitoring systems;
• A change in the account holder’s risk profile;
• Requests received from regulatory or law enforcement authorities.

What an Account Review May Involve

Depending on the nature of the review, the platform may:

• Request updated identity or address verification documents;
• Ask for additional information regarding transaction history;
• Temporarily restrict certain account functions pending the completion of the review;
• Escalate the matter to internal compliance teams or relevant external authorities if necessary.

Account holders will be notified when a review requires their direct input. Cooperation with compliance checks is essential to maintaining uninterrupted account access. The platform’s regulatory requirements mandate that these procedures be conducted thoroughly and without exception.

Account holders using the platform carry a set of responsibilities under the KYC and AML Policy. These responsibilities are fundamental to maintaining the integrity of the platform and to ensuring that each account holder’s own account remains in good standing.

Account holders are expected to:

• Provide accurate information at registration: All personal details entered at the time of account creation must be truthful, complete, and consistent with valid identity documents;
• Maintain up-to-date account information: Any changes to personal details, such as a change of address or surname, should be reported to the platform promptly;
• Cooperate with verification requests: When asked to submit documents or provide additional information, account holders should respond in a timely manner and supply all materials requested;
• Submit authentic documents only: All documents provided during the verification process must be genuine and unaltered;
• Avoid restricted activities: Account holders must refrain from any conduct described in the Restricted Activities section of this policy;
• Use only personally owned payment methods: Deposits and withdrawals must be conducted using payment instruments registered in the name of the account holder;
• Notify the platform of relevant changes: If an account holder becomes aware of any unauthorised access or suspicious activity on their account, this should be reported without delay.

Failure to meet these responsibilities may result in verification delays, account restrictions, or permanent account closure at the platform’s discretion.

Personal data and documents submitted as part of the verification process are handled with care and in accordance with applicable data protection obligations. The platform applies security measures designed to protect submitted information from unauthorised access, loss, or misuse.

How Submitted Information Is Handled

• Documents and personal data are accessed only by authorised personnel responsible for compliance and verification functions;
• Submitted materials are used solely for the purposes of identity verification, AML compliance, and related regulatory obligations;
• Information is not shared with third parties except where required by law, regulatory authority, or as part of the platform's reporting obligations under the AML/CFT Act;
• Data storage practices are aligned with the platform's broader Privacy Policy and applicable New Zealand privacy legislation, including the Privacy Act 2020.

Security Measures in Place

The platform applies technical and organisational security measures to protect stored documents and personal information. These measures are reviewed periodically to ensure they remain appropriate to the nature of the data being held.

Account holders are encouraged to review the platform's Privacy Policy for a more detailed explanation of how personal data is collected, stored, and used across all platform functions. Any queries regarding data handling during the verification process may be directed to the platform's support or compliance team.

The KYC and AML Policy of 1w may be revised from time to time to reflect changes in regulatory requirements, industry standards, or the platform’s internal compliance procedures.

Reasons for Policy Revisions

Updates to this policy may occur as a result of:

• Amendments to New Zealand’s AML/CFT Act or associated regulations;
• Changes to international standards governing anti-money laundering and counter-terrorism financing;
• Updates to the platform’s licensing conditions;
• Internal reviews of compliance procedures and risk management practices.

How Account Holders Are Informed

When a material update is made to this policy, account holders may be notified through one or more of the following methods:

• A notification displayed upon login to the platform;
• An email communication to the registered account address;
• An updated version of the policy published on the platform’s website with a revised effective date.

Account holders are responsible for reviewing the most current version of this policy. Continued use of the platform following the publication of an updated policy constitutes acceptance of the revised terms. The most recent version of this policy is always available on the platform’s website and supersedes all prior versions.