"A" Spine Investments Ltd
Anti-Money Laundering (AML) Program:
Compliance and Supervisory Procedures

Last update: 07/03/2025

UP-X is fully committed to maintaining a secure, transparent, and lawful environment for all our players. As part of this commitment, we adhere to strict Anti-Money Laundering (AML) regulations to prevent any form of financial crime, including money laundering and terrorist financing. This policy outlines the steps we take to prevent, detect, and report suspicious activities related to our online casino services.

2. AML Compliance Objectives

The objectives of this AML policy are to:

• Prevent the use of our platform for money laundering, terrorist financing, or other illicit financial activities;
• Ensure compliance with all applicable AML laws, regulations, and industry standards;
• Establish processes to monitor and report suspicious activities.
• Protect the reputation and integrity of our platform.

3. Know Your Customer (KYC)

To ensure the identity and legitimacy of our players, we implement a robust KYC process. This includes:

• Identity Verification: Players must undergo a KYC process upon registration, submitting valid identification and supporting documents to confirm their identity, age, and location.
• Additional checks: For high-risk players or transactions, we may perform more detailed checks to assess the risk of money laundering or other financial crimes, including but not limited to proof of address and/or proof of source of wealth.
• Ongoing Monitoring: Players’ accounts and transactions are continuously monitored for suspicious activity.

For more information refer to KYC Policy.

4. Transaction Monitoring

We conduct real-time monitoring of all transactions, including deposits, withdrawals, and betting activities, to detect any unusual or suspicious behavior, such as:

• Large, unexplained deposits or withdrawals;
• Patterns that suggest layering or structuring of transactions;
• Frequent transactions from high-risk countries or jurisdictions known for money laundering.

5. Risk Assessment and Classification

All players are assessed based on their risk profile, factors including but not limited to:

• The country of residence or origin.
• Transaction behavior and volume.
• The source of funds and financial history.

6. Suspicious Activity Reporting

If any suspicious activity is detected that could indicate money laundering or other financial crimes, we will:

• Investigate the matter internally.
• Report the suspicious activity to the relevant regulatory authorities in compliance with legal requirements.
• Suspend or freeze accounts if necessary, pending further investigation.

7. Record Keeping

We will maintain detailed records of all KYC documents, transaction histories, and reports of suspicious activities. These records will be stored securely for a period of at least five years or as required by applicable law. This allows us to comply with regulatory audits and ensure transparency in our AML efforts.

8. AML Policy Review and Updates

We regularly review and update our AML policy to ensure it remains in compliance with current laws, regulations, and industry standards. This policy is also subject to continuous improvement based on evolving financial crime prevention techniques and regulatory changes.

9. Player Cooperation

Players are required to cooperate fully with our AML procedures, including submitting requested documents for verification and complying with any additional checks or measures we may take to ensure the integrity of their account and transactions. Failure to cooperate may result in account suspension, closure, or the withholding of funds.

UP-X is dedicated to maintaining a safe and secure environment for all users by preventing financial crime and complying with AML regulations. This policy is part of our ongoing commitment to providing a trustworthy and responsible gaming platform.