KYC & AML Policy

Effective Date: June 1, 2025
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros

IOGr B.V. (“Company”, “we”, “our”, or “us”) operates the website eatuptheborders.com, including all associated subdomains, tools, and services (collectively, the “Website”). This Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) Policy explains how we identify, verify, and monitor our B2B clients to meet regulatory obligations and prevent misuse of our services for money laundering, terrorist financing, or other illicit activity.

1. Purpose and Scope

This Policy sets out our KYC/AML procedures designed to mitigate financial-crime risks. It applies to all B2B partners—operators, resellers, service integrators, platform providers, and other corporate clients—engaging with the Company.

2. Risk-Based Approach (RBA)

We apply a structured risk-based framework during onboarding and throughout the client relationship. Each client’s risk profile is assessed considering (without limitation):

  • Incorporation and operating jurisdictions;
  • Ownership and control (including UBOs and any nominee arrangements);
  • Business model, product mix, customer base, and distribution channels;
  • Regulatory history and adverse media;
  • Transaction behavior (as available).

Based on this assessment, clients are assigned to Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD). Risk profiles are reviewed at least annually, and sooner upon any material change (e.g., new UBOs, restructuring, relocation, licensing changes).

3. Due Diligence Requirements

3.1 Customer Due Diligence (CDD)

Clients must provide current (dated within the last 3 months, where applicable) documents and information, including:

  • Certificate of Incorporation or official Trade Register extract;
  • Memorandum and/or Articles of Association;
  • Proof of business address (e.g., utility bill or bank statement);
  • Corporate structure chart identifying shareholders and Ultimate Beneficial Owners (UBOs);
  • Identification for directors and UBOs (each >25% ownership):
    • Government-issued photo ID (passport or national ID); and
    • Proof of residence (e.g., utility bill or bank statement).

3.2 Enhanced Due Diligence (EDD)

EDD applies when high-risk indicators are present, including (non-exhaustive):

  • Operations linked to FATF high-risk or non-cooperative jurisdictions;
  • Complex or opaque ownership (e.g., nominees, layered offshore holdings);
  • Politically Exposed Person (PEP) involvement or close associates/family members;
  • Adverse regulatory history, sanctions exposure, or significant negative media.

EDD may require additional documentation and checks, such as:

  • Source of Funds (SoF) / Source of Wealth (SoW) evidence for the business and UBOs;
  • Independent/third-party AML audit reports or compliance attestations;
  • Proof of relevant gaming or operating licences and certifications;
  • Extended background, sanctions, and reputational screening.

4. Ongoing Monitoring

All B2B clients are subject to periodic reviews (at least annually) and event-driven reviews following significant changes (e.g., ownership, jurisdiction, licensing). Where unusual or suspicious activity is detected, we may suspend services pending investigation and request further information. Clients must promptly notify us of any legal, structural, or operational changes relevant to their risk profile.

5. PEP and Sanctions Screening

Directors and UBOs are screened against global sanctions and PEP lists (e.g., UN, EU, OFAC) and reputable data vendors. Positive matches or material adverse findings may lead to EDD, onboarding refusal, service suspension, and/or reporting, as applicable.

6. Recordkeeping

We retain KYC/AML records (in physical or digital form) for a minimum of six (6) years after termination of the business relationship, in accordance with applicable Anjouan AML requirements.

7. Restricted Jurisdictions

We do not onboard clients that are registered in, owned or controlled by persons from, or otherwise connected to:

  • FATF high-risk or non-cooperative jurisdictions;
  • Countries or regions subject to UN, EU, or OFAC sanctions;
  • The Union of the Comoros (for white-label services aimed at that jurisdiction);
  • Other territories restricted by the Anjouan Offshore Financial Authority.

8. Failure to Comply

Failure to provide accurate, complete, and timely KYC/AML information may result in one or more of the following actions:

  • Rejection of onboarding;
  • Temporary suspension of services;
  • Termination of the business relationship;
  • Notifications or reports to competent authorities, where required by law.

9. Amendments

We may update this Policy to reflect legal, regulatory, or operational changes. Material updates will be communicated to clients in advance when feasible. The most current version will be available on the Website and becomes effective upon posting unless otherwise stated.