Anti-Money Laundering & KYC Policy

MiJugada.com is operated by COMERCIALIZADORA MIJUGADA.COM, C.A, a company duly incorporated under the laws of the Bolivarian Republic of Venezuela.

The company is committed to preventing money laundering, terrorist financing, fraud, and financial crime. MiJugada.com applies a risk-based Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) framework in accordance with:

• The Organic Law Against Organized Crime and Terrorism Financing (LOCDOFT)
• Regulations issued by the Comisión Nacional de Lotería (CONALOT)
• Applicable Venezuelan AML legislation
• International AML best practices

MiJugada.com has formally appointed an independent Compliance Officer in accordance with Venezuelan AML legislation and CONALOT regulations.

Independence and authority:

• Operates independently from commercial and operational areas
• Has autonomous authority to enforce AML/CTF controls
• Performs duties without interference from commercial management

Key responsibilities include:

• Designing, implementing, updating, and supervising the AML/CTF program
• Maintaining AML/KYC policies, procedures, and internal controls
• Overseeing transaction monitoring and investigation workflows
• Ensuring sanctions and PEP screening processes are applied
• Submitting Suspicious Activity Reports (SAR) to the Unidad Nacional de Inteligencia Financiera (UNIF) when required by law
• Supervising staff training and awareness programs
• Acting as primary liaison with competent authorities (including CONALOT and UNIF)

All customers must undergo identity verification. MiJugada.com applies KYC at registration and on a risk-based basis.

Information collected at onboarding may include:

• Full legal name
• Date of birth
• Nationality
• Email and phone number
• Account credentials and basic profile data

When verification is triggered (e.g., prior to withdrawals or due to risk indicators), users must submit:

• Government-issued ID (passport, national ID, or driver's license)
• Selfie (liveness/face verification) holding the ID where applicable
• Additional verification documents when required

Document quality requirements:

• Clear, legible, and authentic
• All four corners of the ID visible
• Information must be readable

When required, users must submit a document issued within the last 3 months, such as:

• Utility bill
• Bank statement
• Government-issued residence confirmation

The document must clearly show:

• Full name
• Address
• Issue date

Only individuals aged 18 years or older may register and use MiJugada.com services.

If a minor account is detected:

• The account will be immediately suspended
• Funds may be withheld pending investigation and regulatory obligations

EDD is applied when one or more risk factors are present, including:

• Cumulative deposits exceeding USD 5,000 (or equivalent)
• Unusual or suspicious transaction patterns
• PEP status
• High-risk jurisdictions
• Adverse media or fraud indicators

SoF/SoW documentation may be requested, such as:

• Employment verification
• Business ownership documentation
• Investment records
• Other supporting financial evidence

Accounts may be restricted until EDD is satisfactorily completed.

MiJugada.com performs screening against:

• International sanctions lists
• PEP databases
• High-risk jurisdiction lists

If screening indicates unacceptable risk, MiJugada.com may:

• Restrict account activity
• Freeze withdrawals pending review
• Suspend or terminate the business relationship, as permitted by law

MiJugada.com applies ongoing monitoring to detect unusual activity, including:

• Rapid deposit/withdrawal cycles
• Irregular betting behavior inconsistent with the customer profile
• Use of multiple payment methods without clear rationale
• Suspicious account behavior, identity inconsistencies, or device/IP anomalies

MiJugada.com reserves the right to restrict or prohibit access from jurisdictions considered high-risk or prohibited under applicable regulations and internal risk assessments.

All suspicious transactions are internally escalated and reviewed by the Compliance Officer.

Where required by law, Suspicious Activity Reports (SAR) are submitted to the Unidad Nacional de Inteligencia Financiera (UNIF) in accordance with Venezuelan AML regulations.

MiJugada.com retains:

• KYC/identity verification records
• Transaction records

for a minimum of ten (10) years, in line with AML obligations.

Relevant employees receive periodic AML/CTF training covering:

• AML/CTF risk awareness and typologies
• Customer due diligence (CDD/EDD) procedures
• Suspicious activity red flags and escalation
• Data handling and confidentiality requirements
• Internal reporting and documentation standards