1. Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to establish and maintain effective controls to prevent, detect, and report money laundering and terrorist financing activities on the 89PHP IO platform. We are fully committed to complying with the Anti-Money Laundering Act of 2001 (Republic Act No. 9160), as amended, and all relevant implementing rules and regulations issued by the Anti-Money Laundering Council (AMLC) and the Philippine Amusement and Gaming Corporation (PAGCOR).

This policy applies to all players, employees, and third-party partners of 89PHP IO. It is our obligation to protect the integrity of our platform and the Philippine financial system from illicit financial activities.

2. Compliance with Philippine AML Laws

89PHP IO operates under a PAGCOR license and is classified as a covered person under the AMLC's regulatory framework. As such, we are required to implement a comprehensive AML compliance program that includes:

• Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures.
• Ongoing transaction monitoring and analysis.
• Reporting of suspicious transactions to the AMLC.
• Record keeping and document retention for at least five (5) years.
• Annual AML training for all employees.
• Independent AML audits and risk assessments.

Our AML Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. All employees are required to report any suspicious activity to the Compliance Officer immediately.

3. Customer Verification (Know Your Customer – KYC)

To prevent money laundering and identity fraud, 89PHP IO enforces strict Know Your Customer (KYC) procedures. All players are required to provide accurate and verifiable information upon registration and before any withdrawal can be processed.

Our KYC process includes:

• Identity Verification: Government-issued ID (e.g., Philippine Driver's License, Passport, UMID, PRC ID, or Postal ID).
• Address Verification: Utility bill or bank statement (dated within the last three months).
• Mobile Number Verification: OTP (One-Time Password) verification during registration and withdrawals.
• Source of Funds (optional): In certain cases, we may request additional information to verify the legitimate source of funds.

We reserve the right to suspend accounts or withhold withdrawals if KYC documentation is not provided within a reasonable timeframe or if the documentation appears fraudulent.

4. Transaction Monitoring

89PHP IO employs a real-time transaction monitoring system to detect unusual, irregular, or suspicious transactions. Our system analyzes player behavior, deposit and withdrawal patterns, and betting activity to identify potential money laundering or terrorist financing red flags.

Examples of suspicious transaction indicators include:

• Multiple deposits from different payment methods in a short period.
• Deposits made from a source that does not match the registered player's identity.
• Unusually large or frequent transactions that are inconsistent with the player's profile.
• Rapid deposit and withdrawal activity with minimal gameplay (deposit churning).
• Use of multiple accounts by the same individual.

Any transactions flagged as suspicious are reported to our AML Compliance Officer for further investigation. If necessary, we will file a Suspicious Transaction Report (STR) with the AMLC in accordance with applicable laws.

5. Reporting Suspicious Activities

In compliance with the Anti-Money Laundering Act, 89PHP IO has a legal obligation to report suspicious transactions to the Anti-Money Laundering Council (AMLC). A transaction is considered suspicious if it has no apparent legitimate purpose, is inconsistent with the player's known profile, or involves funds that may be derived from illegal activities.

Our reporting process includes:

• Internal investigation by the AML Compliance Officer.
• Filing of a Suspicious Transaction Report (STR) or Covered Transaction Report (CTR) with the AMLC within the required timeframe.
• Confidentiality: We do not disclose to any player that we have filed a report.

We also cooperate fully with AMLC, PAGCOR, and other law enforcement agencies in their investigations.

6. Record Keeping

To ensure full traceability and compliance, 89PHP IO maintains comprehensive records of all player transactions, KYC documents, and communication logs. All records are retained for a minimum of five (5) years from the date of the transaction or account closure, as required by Philippine law.

Records we maintain include:

• Player identification and KYC documents.
• Transaction history, including deposits, withdrawals, and gameplay records.
• Correspondence with players, including support tickets and compliance inquiries.
• Internal AML investigation reports and STR/CTR filings.

All records are stored securely, with access restricted to authorized personnel only. We ensure compliance with the Privacy Policy in handling personal data.

7. Risk Assessment

89PHP IO conducts regular AML risk assessments to identify and mitigate vulnerabilities in our operations. We evaluate risks associated with:

• Player Risk: Based on geographic location, transaction volume, and player behavior.
• Geographic Risk: Jurisdictions with weak AML controls or known money laundering risks.
• Product Risk: Games that may be more susceptible to exploitation (e.g., peer-to-peer games, high-stakes games).

Based on these assessments, we adjust our AML controls, enhance monitoring for high-risk players, and implement additional verification measures when necessary.

8. Account Restrictions and Freezing

To protect our platform and comply with AML regulations, 89PHP IO reserves the right to impose account restrictions or freeze accounts in the following circumstances:

• Failure to complete KYC verification within the required timeframe.
• Suspected money laundering, fraud, or identity theft.
• Transactions flagged as suspicious by our monitoring system.
• Court orders or law enforcement requests to freeze or restrict accounts.
• Violation of our Terms of Service.

If an account is frozen, the player will be notified (unless prohibited by law). Funds will be held pending investigation, and if no illegal activity is confirmed, the account may be unfrozen and funds released. In confirmed cases of money laundering, we are obligated to report the matter to the AMLC and take appropriate legal action.

9. User Responsibilities

All 89PHP IO players have an important role in preventing money laundering. By using our platform, you agree to the following responsibilities:

• Provide truthful and complete information during registration and KYC verification.
• Update your account information promptly if there are any changes (e.g., address, contact details).
• Ensure that all funds deposited into your 89PHP IO account are from a legitimate and legal source.
• Never use multiple accounts or impersonate another person.
• Report any suspicious activity or unauthorized access to your account immediately to our support team.
• Comply with all applicable laws and regulations, including the Anti-Money Laundering Act.

Failure to adhere to these responsibilities may result in account suspension, forfeiture of funds, or legal action.

10. AML Compliance Officer Contact

If you have any questions or concerns regarding this Anti-Money Laundering Policy, or if you wish to report suspicious activity, please contact our AML Compliance Officer:

Email: aml@89php.io
Phone: +63 (2) 1234 5678

All communications will be handled with strict confidentiality.

At 89PHP IO, we are committed to maintaining the highest standards of integrity, transparency, and compliance. Our Anti-Money Laundering Policy is a cornerstone of that commitment, ensuring that our platform remains a safe and trustworthy environment for all Filipino players.