RollNest Anti-Money Laundering (AML) Policy

This Policy applies to all users, accounts, products, transactions and operations involving RollNest.

The key objectives of this Policy are to:

• Detect, deter and respond to money laundering, terrorist financing and related financial‑crime activities;
• Comply with global AML regulations and standards, including FATF recommendations and relevant local laws;
• Protect the RollNest ecosystem, its users and stakeholders from being misused for criminal purposes.

RollNest seeks to align its AML framework with international standards and applicable regulations in jurisdictions where RollNest services are lawfully offered, and with relevant sanctions regimes (such as UN, OFAC and EU lists).

We conduct periodic risk assessments to identify, evaluate and mitigate AML‑related vulnerabilities within our products, services and user base.

3.1 Know Your Customer (KYC) Requirements

• All users must provide a valid email address and basic personal information to create an account.
• We may apply a risk‑based, tiered approach to user verification, requiring government‑issued ID and proof of address for higher‑risk or higher‑value activity.
• We reserve the right to require KYC verification at any time, regardless of transaction size, where suspicious activity is detected or required for regulatory reasons.

3.2 Transaction Monitoring

Automated systems monitor deposits, withdrawals, wagers, and other relevant transactions on an ongoing basis to identify unusual patterns such as large transfers, structuring, rapid movement between tokens or wallets, or behaviour inconsistent with a user’s typical profile. Where applicable, we may use blockchain‑analytics tools to help trace fund flows and identify connections to high‑risk or sanctioned addresses.

Accounts involved in potentially suspicious transactions may be temporarily frozen or restricted pending review, and users may be asked to provide additional information.

3.3 High‑Risk Users and Regions

RollNest prohibits services to users from sanctioned or otherwise restricted countries or territories and may apply enhanced due‑diligence measures to users from high‑risk jurisdictions, including additional documentation, lower transaction limits and ongoing reviews.

3.4 Source of Funds and Withdrawals

For higher‑value deposits and withdrawals, RollNest may request information and documentation regarding the lawful source of funds. Withdrawals may be delayed, limited or refused where verification checks are incomplete or where there are reasonable grounds to suspect illicit activity.

3.5 Reporting and Record‑Keeping

Suspected money laundering, terrorist financing or other criminal activity may be reported internally to the AML Compliance Officer and, where required, to relevant regulatory or law‑enforcement authorities. User identification records, transaction logs and other relevant AML data are stored securely for at least the minimum period required by applicable law.

RollNest appoints a designated AML Compliance Officer responsible for overseeing implementation and ongoing effectiveness of this Policy, conducting risk assessments, coordinating internal investigations and ensuring compliance with reporting obligations.

Relevant employees receive periodic AML training to recognise, prevent and report suspicious activities.

This AML Policy is made available on rollnest.io to inform users of our compliance obligations and their responsibilities. Users are expected to use RollNest’s Services responsibly and lawfully and must not use the platform for illegal purposes.

User data and AML‑related records are encrypted and stored securely, with access restricted to authorised personnel only, in line with applicable data‑protection and privacy regulations. RollNest encourages or may require the use of two‑factor authentication (2FA) to reduce the risk of unauthorised access.

RollNest conducts periodic internal audits and, where appropriate, third‑party reviews to assess the effectiveness of its AML framework. This Policy is reviewed and updated as needed to reflect changes in law, standards, risks and products.

Users who violate this Policy or who are reasonably suspected of involvement in money laundering, terrorist financing or other criminal activity may be subject to warnings, additional checks, account restrictions or suspension, freezing or withholding of funds (where permitted by law), account closure and reporting to authorities.

If you have any questions about this AML Policy or wish to report suspicious activity related to RollNest, please contact us through the Support Portal available on rollnest.io or via support@rollnest.io.