KYC & ANTI-MONEY LAUNDERING (AML) POLICY

1. INTRODUCTION

This KYC (Know Your Customer) and AML (Anti-Money Laundering) Policy outlines the procedures implemented by Spintall Network Solutions ("Spintall," "we," "us") to prevent fraud, money laundering, terrorist financing, and other illicit activities on the Arena 26 Platform ("Platform").

This Policy is designed in line with applicable Nigerian regulations and international AML standards.

2. PURPOSE

The purpose of this Policy is to:

• Verify user identities
• Prevent misuse of the Platform for illegal activities
• Ensure transparency in transactions and user activity
• Protect the integrity of Arena 26

3. SCOPE

This Policy applies to:

• All users of Arena 26
• Host/Creator accounts
• All transactions involving platform tokens or value systems

4. KYC REQUIREMENTS

5. KYC TRIGGERS

KYC may be required:

• At account registration (optional or mandatory depending on rollout stage)
• Before withdrawals or payouts
• When transaction thresholds are exceeded
• When suspicious activity is detected
• For Host/Creator accounts (mandatory)

6. HOST ACCOUNT VERIFICATION

All Host Users must:

• Complete full KYC verification
• Provide accurate personal information
• Comply with ongoing monitoring

7. AML MONITORING

Spintall uses automated and manual systems to monitor:

• Unusual gameplay patterns
• Rapid or repetitive transactions
• Coordinated or suspicious user interactions
• Abnormal win/loss distributions
• Multi-account or collusion behavior

8. SUSPICIOUS ACTIVITY

The following may be considered suspicious:

• Use of multiple accounts to manipulate outcomes
• Coordinated gameplay between linked users
• Unusual transaction volumes or patterns
• Attempts to bypass system controls
• Providing false or misleading information

9. ACTIONS ON SUSPICIOUS ACTIVITY

Spintall reserves the right to:

• Freeze accounts
• Delay or withhold payouts
• Request additional verification
• Restrict account functionality
• Report activity to relevant authorities

10. TRANSACTION MONITORING

The Platform may:

• Set transaction limits
• Apply automated risk scoring
• Flag high-risk behavior
• Temporarily hold funds for review

11. RECORD KEEPING

Spintall maintains records of:

• User identification data
• Transaction history
• Risk assessments
• Suspicious activity reports

Records are retained as required by applicable laws.

12. SANCTIONS COMPLIANCE

Users must not:

• Be listed on international sanctions lists
• Use the Platform for restricted or illegal purposes

Spintall may screen users against relevant databases.

13. USER RESPONSIBILITIES

Users agree to:

• Provide accurate information
• Update details when required
• Cooperate with verification requests
• Avoid engaging in suspicious or illegal activity

14. DATA PRIVACY

All KYC data is handled in accordance with our Privacy Policy.

• Data is securely stored
• Access is restricted
• Information is not sold

15. NON-COMPLIANCE

Failure to comply with this Policy may result in:

• Account suspension or termination
• Loss of access to funds or rewards
• Legal reporting where applicable

16. POLICY UPDATES

Spintall reserves the right to update this Policy at any time.

Continued use of the Platform constitutes acceptance of updates.

17. CONTACT

For KYC/AML inquiries: