Effective Date: June 1, 2025
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros
This Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy sets out the principles, controls, and procedures applied by IOGr B.V. (“Company”, “we”, “our”, or “us”) in connection with the operation of sauver-ukraine.ca, including all related domains, platforms, and services (collectively, the “Website”).
The purpose of this Policy is to ensure compliance with applicable regulatory requirements and to reduce the risk that our services are misused for money laundering, terrorist financing, fraud, or other unlawful activities.
1. Scope of Application
This Policy applies to all business-to-business (B2B) relationships entered into by the Company, including but not limited to:
- Licensed gaming and betting operators
- White-label and platform partners
- Distributors, resellers, and aggregators
- Software, infrastructure, and integration providers
- Other corporate or institutional counterparties
The Company does not provide services directly to individual players. Accordingly, this Policy does not apply to end-user customers.
2. Risk-Based Compliance Approach
The Company adopts a risk-based approach (RBA) to identify, assess, and manage financial crime risks throughout the lifecycle of each business relationship.
Risk assessments may consider a range of factors, including:
- Country of incorporation and operational jurisdictions
- Ownership and control structure, including Ultimate Beneficial Owners (“UBOs”)
- Nature of the business model, products, and target markets
- Regulatory licensing status and supervisory oversight
- Reputational risk and adverse media exposure
- Transaction behaviour, where applicable
Based on this assessment, clients are classified as presenting either standard or elevated risk. The level of due diligence applied corresponds to the assessed risk profile.
Risk profiles are reviewed at least annually and whenever a material change occurs.
3. Customer Due Diligence (CDD)
Before onboarding, all prospective clients are required to undergo Customer Due Diligence.
As part of the CDD process, the Company may request documentation including:
- Certificate of Incorporation or equivalent registration document
- Extract from a recognised commercial or trade register
- Articles and/or Memorandum of Association
- Proof of registered business address
- Corporate ownership and control structure diagram
- Identification details of directors and key decision-makers
For each Ultimate Beneficial Owner holding 25% or more ownership or control, the following documentation is required:
- Valid government-issued photographic identification
- Proof of residential address
All documentation must be accurate, complete, and current, typically issued within the last three (3) months where applicable.
4. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied where higher financial crime risk indicators are identified.
Circumstances that may trigger EDD include, but are not limited to:
- Links to jurisdictions classified as high-risk or non-cooperative by the FATF
- Complex, layered, or opaque ownership structures
- Involvement of Politically Exposed Persons (PEPs), their close associates, or family members
- Prior sanctions exposure, regulatory enforcement actions, or significant adverse media
EDD measures may include:
- Verification of Source of Funds (SoF) and Source of Wealth (SoW)
- Confirmation of valid operating or gaming licences
- Independent AML or compliance audit reports
- Expanded sanctions, PEP, and reputational screening
The Company reserves the right to refuse onboarding or terminate relationships where risks cannot be adequately mitigated.
5. Ongoing Monitoring
All active client relationships are subject to ongoing monitoring to ensure continued compliance with KYC and AML requirements.
Monitoring activities may include:
- Periodic review and updating of KYC documentation
- Event-driven reviews following changes in ownership, management, jurisdiction, or licensing
- Identification and assessment of unusual or inconsistent activity
Clients are required to promptly notify the Company of any changes that may affect their risk profile.
6. Sanctions and PEP Screening
The Company screens directors, shareholders, and UBOs against applicable international sanctions and PEP databases, including those maintained by the United Nations, European Union, and OFAC, as well as reputable third-party screening providers.
Confirmed matches or material adverse findings may result in enhanced due diligence, suspension of services, refusal of onboarding, or reporting to competent authorities where required by law.
7. Record Retention
KYC and AML records are retained securely in electronic or physical form for a minimum period of six (6) years following the termination of the business relationship, in accordance with applicable regulatory requirements.
8. Restricted Jurisdictions
The Company does not establish or maintain business relationships with entities that are:
- Registered in, operating from, or controlled by FATF high-risk or non-cooperative jurisdictions
- Subject to United Nations, European Union, or OFAC sanctions
- Operating within the Union of the Comoros for white-label services targeting that jurisdiction
- Otherwise restricted by the Anjouan Offshore Financial Authority
9. Consequences of Non-Compliance
Failure to provide accurate, complete, or timely KYC/AML information may result in:
- Refusal to onboard
- Temporary or permanent suspension of services
- Termination of contractual relationships
- Reporting to regulatory or law enforcement authorities where legally required
10. Policy Updates
This Policy may be amended from time to time to reflect changes in applicable laws, regulations, or internal compliance practices. The most current version will always be available on the Website and becomes effective upon publication unless stated otherwise.