Anti-Money Laundering Policy

1. Purpose and Scope

This policy explains how SHINDIVO prevents its platform from being used to launder money, to finance terrorism, or to move the proceeds of crime.

SHINDIVO is operated by Shop and Deliver Limited, a licensee of the Gambling Regulatory Authority of Kenya (GRA) holding licence numbers BK-00011111 and PG-0001110. As a licensee we are subject to the Proceeds of Crime and Anti-Money Laundering Act and to the internal control obligations set out in the Gambling Control (Conduct of Gambling Operations) Regulations, 2026.

The policy applies to every account, every deposit and withdrawal, and every member of staff. It applies whether you bet on sport, play casino games, or hold a balance without playing.

We maintain internal control systems designed to detect and prevent money laundering, terrorism financing and fraud in our operations, as regulation 98 of those Regulations requires.

This is a summary written for players. The full internal programme, including thresholds, scoring rules and escalation paths, is confidential: publishing it would tell the people we are trying to stop exactly where our thresholds sit.

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2. What Money Laundering Means Here

Money laundering is the process of making funds obtained through crime appear to have a lawful source. A gambling account can be attractive for this because money goes in, a small amount is wagered, and what comes out looks like winnings.

Terrorism financing is the provision of funds for terrorist acts, whatever the origin of the money. The controls in this policy address both.

You do not need to be a criminal to trigger a control. Patterns matter: an account funded heavily and cashed out with little or no betting looks the same to a monitoring system whether the intent is criminal or not.

Where a control is triggered, we act on the pattern. We will ask you for information, and we may restrict the account while we look at it.

3. Know Your Customer

We are required to verify the identity of every player in accordance with the know-your-customer requirements of the Proceeds of Crime and Anti-Money Laundering Act. This is not optional for us and cannot be waived at your request.

Before an account is activated and before we accept any wagering deposit, we verify your identity, your age and your location using reliable, independent and electronically verifiable sources.

We require a valid Kenyan national identity card or passport. We may require a photograph of you holding the document, a recent proof of address, and confirmation that the payment method belongs to you.

Anonymous gambling is prohibited. We do not operate anonymous accounts, and we do not accept virtual assets or cryptocurrency for deposit or withdrawal.

We verify the identity of every winner before winnings are paid. This applies even where the account was verified when it was opened.

Information you give us must be true and current. If you tell us something that is false at registration, the account is cancelled and any resulting winnings are forfeit.

Where our checks indicate higher risk, we apply enhanced due diligence: additional documents, questions about the source of the funds, and closer monitoring of the account.

4. Source of Funds and Source of Wealth

We may ask you to show where the money you are gambling with came from. This is a standard anti-money-laundering measure, not an accusation.

We ask for source of funds where the amounts involved are large relative to what we know about you, where deposits do not match the way the account plays, or where a withdrawal falls into a tier that requires enhanced checks.

Acceptable evidence includes payslips, bank or mobile money statements, a tax return, a sale agreement, or similar documents that connect the money to a lawful source.

Where you cannot or will not show a lawful source for funds we have reason to question, we may decline the transaction, restrict the account, and report the matter where the law requires us to.

We are not permitted to tell you that a report has been made about your account, and we cannot discuss the contents of such a report with you.

5. Payment Controls

We process all financial transactions through a secure payment gateway compliant with the payment card industry data security standard, using payment providers licensed by the Central Bank of Kenya.

You may deposit only from a payment method held in your own name. Deposits from a third party are returned to source and are not made available for betting.

Withdrawals are paid only to a payment method held in your own name. We do not pay a third party on your instruction, whatever the reason given.

We do not accept cash, credit cards, or credit advanced by us. Kenyan law prohibits a licensee from inducing or facilitating gambling through credit; free bets and bonus bets are the only exceptions and are not credit.

Funds deposited and then withdrawn with little or no betting may be returned to their source rather than paid as winnings. A gambling account is not a money transfer service and we may not allow it to be used as one.

Payment instructions require multi-factor authentication, such as a one-time password, before they are executed.

Where a deposit or a charge fails, is cancelled or is made in error, we operate a clear refund process and return the money to its source.

6. Transaction Monitoring

Account and transaction activity is monitored continuously by automated systems and reviewed by our compliance staff.

Among the patterns our systems look for are: deposits followed by withdrawal with minimal play; structured deposits that appear designed to stay under a threshold; repeated payments inconsistent with normal participation; betting on both sides of a market to neutralise risk; sudden changes in the size or frequency of transactions; and multiple accounts funded by the same payment instrument.

We do not publish our thresholds, our scoring rules, or the number of indicators required before a case is escalated. Publishing them would let anyone intending to launder money stay just below them.

Records of tickets accepted and settled, of financial transactions, of player accounts and of complaints are kept and maintained as our licence requires, and are available to the Authority for inspection.

A review may be triggered by our systems, by a member of staff, by a payment provider, or by a request from the Authority or another competent body.

7. Reporting Obligations

We report to the Gambling Regulatory Authority any suspicious activity, transaction or fraud arising in our operations within twenty-four hours of becoming aware of it, as regulation 93 requires.

We also report to the Financial Reporting Centre, the financial intelligence unit established under the Proceeds of Crime and Anti-Money Laundering Act, in the manner and within the time that Act and its regulations require.

A report is made on the basis of suspicion. It is not a finding that you have done anything wrong, and it does not by itself mean your account will be closed.

We are prohibited by law from informing you that a suspicious transaction report has been or may be made. If we decline to explain a restriction in detail, this is why, and it is not evasion.

We designate a money laundering reporting officer, vetted and licensed by the Authority as a key gambling employee, who is responsible for these reports and for the operation of this policy.

Our staff are trained to detect and report suspicious activity, and that training is repeated so that it stays current with the law.

8. Payment of Winnings and Verification Tiers

Kenyan law sets out how prizes are paid according to their size, and the verification that applies to each tier. We follow that schedule; we do not set our own.

Prizes up to KES 500,000 are paid to your registered mobile money wallet or gambling account, subject to basic identity verification, and are completed immediately.

Prizes from KES 500,001 to KES 5,000,000 are paid by mobile money or bank transfer, require government-issued identification and confirmation that the ticket is yours, are subject to basic anti-money-laundering checks, and are completed within five working days.

Prizes from KES 5,000,001 to KES 50,000,000 are paid by bank transfer only, require full identity verification, ticket authentication and enhanced anti-money-laundering checks, may require verification in person or by secure video, and are completed within fourteen working days after verification is complete.

Prizes above KES 50,000,000 are treated as jackpot prizes. Winners are offered financial counselling and secure payment arrangements, structured payouts may be provided, and payment is completed within thirty working days after verification is complete.

No prize is paid without verification of lawful ticket ownership. Verification is a condition of payment, not a reason to withhold one: where your documents are in order and the win is valid, we pay within the period the law sets.

Statutory deductions that apply to gambling transactions in Kenya are applied where the law requires and are shown to you. They are collected on behalf of the Kenya Revenue Authority and are not retained by us.

9. Restrictions We May Apply

Where a control is triggered, we may pause a withdrawal pending verification, request documents, limit deposits or betting, or suspend the account while the matter is examined.

A restriction is applied for as long as the examination reasonably requires and no longer. We tell you what is needed to lift it, except where the law prohibits us from explaining.

We may refuse to open an account, or close an existing one, where we cannot satisfy ourselves as to identity or source of funds.

Where an account is closed for these reasons and the balance is not subject to a legal restriction or a lawful order, the confirmed balance is returned to its source.

Where a court, the Authority, the Financial Reporting Centre or another competent body directs us to freeze or surrender funds, we comply with that direction. In that case the funds are not returned to you and we are not able to release them on your request.

10. Prohibited Conduct

You may not use the platform to move money of unlawful origin, to disguise the source of funds, or to make payments to or through another person.

You may not open or use more than one account, use another person's identity or payment method, or allow another person to use yours.

You may not structure deposits or withdrawals to avoid a threshold, or act with others to do so.

You may not place bets designed to move value between accounts rather than to win, including matched betting between accounts under common control.

Conduct of this kind results in closure of the account, forfeiture of winnings derived from it, and a report to the Authority and, where applicable, to the Financial Reporting Centre.

Where such conduct is established, stakes may be returned where the law requires, but winnings derived from prohibited conduct are not paid.

11. Record Keeping

We keep records of customer information, verification documents, financial transactions, player accounts, complaints and their resolution, and of the reports we make.

Records are kept for the period required by the Proceeds of Crime and Anti-Money Laundering Act, by the gambling regulations, and by the Data Protection Act, whichever is longer for the record concerned.

Records are held securely, access is limited to staff who need it for their role, and access is logged.

Records are made available to the Authority and to other competent bodies on lawful request, and our books are open to inspection by inspectors of the Authority.

Personal data collected for these purposes is processed under our Privacy Policy and is not used for marketing.

12. Governance, Training and Review

Responsibility for this policy sits with our senior management and with the money laundering reporting officer. Directors, shareholders and key gambling employees are vetted by the Authority and must remain fit and proper throughout.

Staff who handle accounts, payments or verification are trained on detecting and reporting suspicious activity, on the identification of vulnerable and self-excluded persons, and on their own reporting duties.

The programme is reviewed regularly, and after any material change to our products, payment methods or applicable law. Independent audits and security tests are carried out as our licence requires.

Where a weakness is found, it is recorded, remediated and the remediation is verified. Incidents, breaches and downtime are recorded in an incident response register.

Questions about this policy may be sent to our support team ([email protected]). We cannot discuss individual reports, but we can explain what a restriction requires from you.

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