Gemwin's AML & KYC Policy is a shield protecting member rights through a rigorous identity verification and anti-money laundering process.

GEMWIN AML & KYC POLICY — THE SHIELD PROTECTING YOUR RIGHTS

Gemwin's AML & KYC policy is a strict set of standards ensuring absolute transparency and security for all transactions. This identity verification process effectively prevents financial fraud or system abuse by malicious actors. It is a firm commitment to protecting member rights within a premium entertainment environment.

OVERVIEW OF GEMWIN'S AML & KYC POLICY

The AML & KYC policy is a transparent financial protection system ensuring absolute security for all transactions. This process accurately identifies members and thoroughly prevents financial fraud. It is a firm commitment to protecting customer rights in a professional entertainment environment.

PURPOSE OF ISSUING THE AML & KYC POLICY

The AML & KYC policy is established to identify, prevent, and limit money laundering, fraud, or exploitation of the platform for non-transparent financial activities. The operations team applies appropriate control measures to protect system integrity and members' legal rights.

Scope of Application

This policy applies to all members using Gemwin's services, including those who have registered accounts, those undergoing information verification, and cases involving system activity. All operations related to account management, financial transactions, or platform utility use fall within the scope of review when AML/KYC checks are required.

AML & KYC Policy Applies to All Gemwin Members

Risk Control Principles During Operations

The control process is implemented according to the risk level of each account, transaction, and service usage behavior. The system maintains regular monitoring to identify early signs of abnormalities while supporting the responsible department to process cases consistently within regulatory scope.

VERIFICATION AND MONITORING PROCESS UNDER AML & KYC POLICY

The verification and monitoring process is systematically and rigorously established to ensure all platform activities are conducted transparently. This process helps identify risks early, tightly control transactions, and protect the safety of all members.

Customer Identity Verification (KYC) at Gemwin

The platform implements a KYC process to ensure each account is created and used by a valid user. Members must provide accurate and complete information; in cases of inconsistent documentation, the system may request additional information or apply appropriate restrictions.

Classifying and Evaluating Account Risk Levels

Accounts are reviewed based on access region, usage behavior, transaction frequency, transaction value, and activity history. When above-normal risk levels appear, the responsible department may increase monitoring or request additional verification.

Monitoring Transactions to Detect Abnormal Behavior

Account activities and transactions are monitored through periodic checks combined with data analysis, helping the responsible department identify early deviations from normal usage. When suspicion arises, the control team may review data, contact for verification, or temporarily restrict certain operations.

Monitoring Transactions to Detect Unusual Signs

SANCTIONS FOR VIOLATIONS AND POST-AUDIT DATA SECURITY

Enforcement measures for violations and post-audit data security are strictly applied to protect the platform and the rights of all members. This system ensures all violations are handled promptly and transparently, with information absolutely protected after inspection.

Sanctions for Suspected Violations

When signs of money laundering, fraud, or operational violations are detected, the management board may apply necessary measures to protect the system and member community. Approaches include transaction restrictions, account suspension, termination of usage rights, or cooperation with competent authorities when valid requests arise.

Standards for Storing Records and Transaction Evidence

KYC information, transaction data, and related records are retained for an appropriate period for risk management, internal reconciliation, and resolution of arising situations. The data department maintains documents to safety standards and limits access beyond the permitted scope.

AML/KYC Data Security Across the Entire System

AML/KYC data collected during verification and monitoring is only accessible to authorized departments for compliance and risk control purposes. The platform does not use this information outside the policy scope, except when required to meet lawful requests from government authorities.

Privacy Protection Principles in the Verification Process

MEMBER RESPONSIBILITIES AND ENFORCEMENT TERMS

Member responsibilities and enforcement terms are clearly defined to ensure compliance from users. This contributes to maintaining a safe, transparent operating environment and protecting the rights of all members.

Member Responsibilities

Members must cooperate with information verification, provide accurate data, and respond promptly when requested by the responsible department. If abnormal signs are detected in an account, users should proactively notify the platform for inspection.

Updated AML & KYC Regulations

The management board has the right to adjust the AML & KYC policy at each stage to align with operational requirements, risk control practices, and relevant regulations. All changes will be publicly announced on the website and take effect from the date of official publication.

Contact Information

For any questions, support requests, or feedback related to the Anti-Money Laundering and Verification Policy, you may submit via the following channels:

• General Support Channel:
• AML/KYC and Compliance Channel:

CLOSING NOTES

The AML & KYC policy is a strong affirmation of commitment to creating a safe, transparent entertainment space that upholds legal values. Member community peace of mind is always the top priority, serving as the foundation for maintaining Gemwin's credibility and sustainable growth.