Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CFT Policy)

Last Updated: December 1, 2025

Email: support@goragaming.com

1. Introduction

This Anti-Money Laundering and Counter-Terrorism Financing Policy (“Policy”) sets out the principles and procedures adopted by Gora Games ME FZ LLC (“Gora Games”, “we”, “us”), to prevent the use of our platform for money laundering, terrorist financing, fraud or any other illegal financial activity.

This Policy operates together with our KYC Policy and Terms and Conditions.

Gora Games operates an online gaming and tournament platform. While Gora Games does not position itself as a financial institution or payment processor, it recognises that its services may involve financial flows and therefore applies proportionate AML/CFT measures.

2. Regulatory basis and standards

This Policy is based on generally recognised international AML/CFT standards, including the recommendations of the Financial Action Task Force (FATF), as well as contractual requirements and risk standards applied by our banking and payment partners.

3. Scope

This Policy applies to:

• all users of the Gora Games platform (“Users”);
• all employees, officers and contractors of Gora Games;
• all activities involving user deposits, withdrawals, prize redemptions, and any other value flows processed through Gora Games’ systems or through the payment providers we cooperate with.

4. Customer due diligence and KYC

4.1. When we perform AML/KYC checks

Gora Games performs AML/KYC checks specifically at the moment when a User requests a withdrawal of funds from the platform.

Withdrawals will not be processed until the User has provided the minimum set of required data and such data has passed our basic checks.

4.2. Data required at withdrawal stage

At the withdrawal stage, we require the User to provide at least the following information:

• full name;
• date of birth;
• banking requisites needed to process the withdrawal (bank account, IBAN, card or other payment details depending on the withdrawal method).

Enhanced procedures may apply when:

• Withdrawal amounts exceed threshold levels
• The User appears on sanctions watchlists
• There is a mismatch between banking details and identity
• The User is located in a high-risk jurisdiction
• The User behaves suspiciously or triggers risk indicators

Gora Games may require additional documentation, such as:

• bank statements;
• occupation details;
• additional identity verification:
  • Proof of identity (passport, national ID card, or equivalent),
  • Proof of age,
  • Proof of address);
• source-of-funds declarations.

4.3. Users under 18 – prohibition of cash-related actions

Gora Games does not permit any cash-related actions or withdrawals for Users under the age of 18.

Any attempt by a User under 18 to withdraw funds or perform cash-related financial actions will be rejected. Where we become aware that an account is used by a person under 18, we may suspend or terminate such account and take appropriate actions in line with our Terms and KYC Policy.

5. Payment providers and AML cooperation

Gora Games cooperates with payment providers to process deposits, withdrawals and other financial flows related to the platform.

Each payment provider applies its own AML/CFT procedures, risk-based controls and monitoring. If a payment provider identifies a red flag, blocks or delays a transaction, or requires additional information from the User, Gora Games:

• respects and follows the decision and requirements of the payment provider;
• may request from the User any additional information or documents required to resolve the situation;
• may suspend or cancel the related transaction and/or account until the issue is resolved.

6. Monitoring and red flags

Gora Games applies ongoing monitoring measures proportionate to the nature of its business, including:

• monitoring of withdrawal patterns;
• identification of unusual or inconsistent behaviour (e.g. rapid deposit and withdrawal with minimal gameplay);
• detection of multiple accounts, possible collusion, or attempts to circumvent rules;
• monitoring of attempts by underage Users to withdraw funds or perform cash-related actions.

Examples of potential red flags include, without limitation:

• multiple withdrawal attempts shortly after deposits;
• use of banking requisites that do not reasonably match the User’s profile;
• repeated failures or refusals to provide required information at withdrawal stage;
• indications that the User may be acting on behalf of third parties without disclosure.

7. Suspicious activity and reporting

Where Gora Games identifies behaviour that it reasonably considers suspicious or inconsistent with normal use of the platform, it may:

• suspend the User’s ability to withdraw funds;
• request additional information;
• block or cancel individual transactions;
• close the User’s account in accordance with our Terms and Policies;
• cooperate with banks, payment providers and competent authorities as required by applicable laws and contractual obligations.

Gora Games does not tolerate the use of its platform for any illegal or abusive activities and may share relevant information with financial institutions and competent authorities in accordance with applicable law.

8. Record keeping

Gora Games stores AML/KYC-related data, transaction data, and communication related to AML/CFT matters for a period of 5 years that is reasonably necessary for:

• compliance with legal and contractual obligations;
• protection of the legitimate interests of Gora Games;
• cooperation with financial institutions and competent authorities, where applicable.

9. Roles and responsibilities

Gora Games maintains internal responsibilities for:

• implementing this Policy in daily operations;
• reviewing and processing AML/KYC information at withdrawal stage;
• liaising with payment providers and banking partners;
• maintaining appropriate logs and records;
• training relevant staff.

10. Suspension and termination of accounts

Gora Games may suspend or terminate a User’s account, block withdrawals, or confiscate prizes if:

• the User fails to provide information required at withdrawal stage;
• the User provides obviously false or misleading information;
• there is a reasonable suspicion that the account is used for illegal activities, money laundering, terrorist financing, fraud or abuse;
• the User is under 18 and attempts to perform cash-related actions.

11. No cash handling

Gora Games does not handle physical cash. All deposits and withdrawals are processed through non-cash payment methods via payment providers. Users under 18 are strictly prohibited from any cash-related actions or withdrawals.

12. Policy review

This Policy may be updated from time to time to reflect changes in laws, industry standards, banking and payment-provider requirements, and the development of Gora Games’ products and services.

13. Contact

For questions relating to this AML/CFT Policy or to AML/KYC matters generally, Users may contact us at: support@goragaming.com