PANDA888 - AML / KYC COMPLIANCE POLICY

Effective Date: January 1, 2025

Last Updated: November 18, 2025

Introduction

PANDA888 ("Panda888", "we", "us", or "our") is committed to complying with applicable Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know-Your-Customer (KYC) regulations to ensure a safe, transparent, and lawful environment for all users of our website, applications, and blockchain-based services (the "Services").

This AML/KYC Policy outlines our procedures for preventing money laundering, terrorist financing, fraud, identity theft, and other illicit activities.

Purpose of the Policy

This Policy is designed to:

  • Prevent Panda888 from being used for criminal or fraudulent activities.

  • Verify the identity and legitimacy of our users.

  • Ensure compliance with applicable global AML/CTF laws.

  • Monitor and detect suspicious activity.

  • Cooperate with regulatory authorities when required.

  • Protect the integrity and reputation of Panda888.

Regulatory Frameworks

Panda888 follows AML/KYC requirements consistent with international standards, including:

  • FATF Recommendations (Financial Action Task Force).

  • FinCEN Guidelines (U.S.).

  • FINTRAC Regulations (Canada).

  • EU AMLD5/AMLD6.

  • UK Anti-Money Laundering Regulations.

  • UN Sanctions Lists.

  • OFAC Sanctions Compliance.

  • This Policy applies regardless of the user's country unless restricted by Section 11.

Scope of the Policy

This Policy applies to:

  • All users of Panda888.

  • All employees, contractors, and partners.

  • All sweepstakes, promotions, contests, and reward systems.

  • Wallet-based payouts, blockchain transactions, and prize distributions.

  • Payment and withdrawal methods.

  • Referral and incentive programs.

Responsibility & Oversight

Compliance Officer

Panda888 appoints a designated Compliance Officer responsible for:

  • Implementing this AML/KYC Policy.

  • Maintaining user identification records.

  • Filing suspicious activity reports (SARs).

  • Conducting ongoing risk assessments.

  • Ensuring staff training and internal audits.

  • Coordinating with law enforcement and regulators.

Staff Training

Staff members who interact with user data or financial transactions must undergo annual AML/KYC training.

Know-Your-Customer (KYC) Requirements

Panda888 requires identity verification in the following situations:

  • Withdrawal of prizes or rewards.

  • Receipt of prizes over a specified value.

  • When suspicious activity is detected.

  • When required by law or regulation.

  • When cumulative transaction thresholds are reached.

  • When a user appears in high-risk jurisdictions.

Required Identification Documents

Users may be required to provide:

  • Primary ID (one of): passport, national ID card, driver's license.

  • Secondary verification (if applicable): proof of address (utility bill, bank statement, etc.), selfie with ID for facial verification, additional documents upon request.

Wallet Verification (for blockchain payouts)

Users may be required to:

  • Verify ownership of a TON or other blockchain wallet.

  • Sign a message or make a micro-transaction.

  • Undergo blockchain analytics screening.

Enhanced Due Diligence (EDD)

Applied when users are:

  • From high-risk countries.

  • Engaged in unusual activity.

  • Politically Exposed Persons (PEP).

  • Large prize winners.

  • Users with inconsistent or unverifiable information.

User Risk Categorization

Panda888 assigns users a risk category:

  • Low Risk - verified identity, standard activity.

  • Medium Risk - limited verification, higher transaction activity.

  • High Risk - high volume, high-risk country, PEP status, or suspicious behavior.

  • High-risk users may require additional verification or may be restricted from using the platform.

Monitoring & Detection of Suspicious Activity

Panda888 uses automated and manual methods to detect:

  • Unusual login patterns.

  • Multiple accounts from one user.

  • Use of VPNs or proxy services.

  • Rapid entry purchases or withdrawals.

  • Attempted circumvention of geographic restrictions.

  • Attempts to manipulate sweepstakes.

  • Large prize claims inconsistent with user behavior.

  • Blockchain wallet addresses linked to illicit activity.

  • Payments from questionable sources.

  • Sudden changes in user behavior.

Suspicious Activity Examples

  • Attempts to withdraw prizes to multiple unrelated wallets.

  • Participation from sanctioned jurisdictions.

  • Large-volume entries purchased from newly created accounts.

  • Evidence of collusion, bots, automation, or fraud.

Potential Outcomes

Suspicious activity may result in:

  • Freezing of account.

  • Withholding of prizes.

  • Reporting to authorities.

  • Permanent account suspension.

Record-Keeping Requirements

We maintain records for a minimum of 5 years, including:

  • User identification data.

  • KYC documentation.

  • Transaction records.

  • Prize distribution logs.

  • IP and device metadata.

  • Suspicious activity reports (SARs).

  • Correspondence related to investigations.

  • Blockchain transactions remain permanently public and cannot be altered.

Sanctions Screening

Panda888 screens users and transactions against:

  • OFAC sanctions lists.

  • UN sanctions lists.

  • EU/UK sanctions lists.

  • Local jurisdiction restrictions.

  • High-risk countries identified by FATF.

  • Users from sanctioned countries are not permitted to use Panda888.

Restricted Jurisdictions

Panda888 does not accept users from:

  • North Korea.

  • Iran.

  • Syria.

  • Cuba.

  • Afghanistan.

  • Crimea / Donetsk / Luhansk regions.

  • Any country sanctioned by the UN, EU, US, UK, or Canada.

  • Participation is prohibited, and accounts may be blocked.

Reporting Obligations

Where required by law, Panda888 may report:

  • Suspicious Activity Reports (SARs).

  • Transactions over regulatory thresholds.

  • Fraudulent or unlawful behavior.

  • Identity mismatches.

  • Use of stolen payment methods.

Cooperation with Authorities

We may cooperate with:

  • Law enforcement.

  • Financial regulators.

  • Tax authorities.

  • Courts of competent jurisdiction.

  • We do not notify users when such reports are filed.

Data Protection & Privacy

All personal information collected under this Policy is handled in accordance with:

  • Our Privacy Policy.

  • Applicable data protection laws (GDPR, PIPEDA, Law 25, etc.).

  • KYC documents are encrypted and stored securely.

User Obligations

By using Panda888, you agree to:

  • Provide accurate and truthful information.

  • Not engage in fraudulent or prohibited activities.

  • Cooperate with verification requests.

  • Use your own identity and payment methods.

  • Follow all applicable laws in your jurisdiction.

  • Failure to comply may result in account termination.

Consequences for Non-Compliance

Panda888 reserves the right to:

  • Freeze or close accounts.

  • Withhold or cancel prizes.

  • Reverse or block transactions.

  • Deny access to future promotions.

  • Report activity to authorities.

  • Block IP addresses or wallets.

  • Enforce permanent bans.

Policy Updates

We may update this AML/KYC Policy periodically. Updates are effective upon posting to the website. Continued use of Panda888 signifies acceptance of the updated Policy.

Contact Information

For questions regarding this Policy:

  • compliance@panda888.io

  • www.panda888.io

  • Telegram Support: @Panda888Support