AML policy

• Legal entity: [LEGAL ENTITY NAME]
• Registered address: [REGISTERED ADDRESS]
• AML contact: [AML/COMPLIANCE EMAIL]
• Last updated date: [DATE]

This AML policy describes how Winnow Lotto helps prevent money laundering, fraud, and other financial crime. We may request identity and address verification before allowing purchases, wallet activity, or payouts.

• We may request your full name, date of birth, address, and proof documents (where required).
• We may use verification providers to validate identity and reduce fraud.
• If verification fails or cannot be completed, we may restrict or suspend service and/or refund where required by law.

• We may monitor transactions for suspicious patterns (e.g., unusual payment activity, repeated reversals, or mismatched identity details).
• We may delay, block, or reverse transactions and payouts where required to investigate.
• We may report suspicious activity to relevant authorities where required by law.

We keep records for the period required by law and legitimate business needs (e.g., accounting and fraud prevention). See our Privacy Policy for more on retention.