KYC Policy

Last update: 07/03/2025

This policy confirms UP-X’s commitment to prevent money-laundering and the financing of terrorism in its business practices and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.

UP-X has established Know Your Counterparty (KYC) procedures to combat money laundering (AML) and the financing of terrorism (CTF). These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity.

The head of the Security Department is responsible for development and implementation of this policy and relevant procedures, and UP-X commits to review KYC policy and procedure every year.

To support our KYC policy and procedures, UP-X has developed a KYC form which we send to all our counterparties (this is our business partners: suppliers and customers) to collect relevant information to identify risks of money-laundering. We require the form to be completed for all existing and new counterparties.

By collecting and reviewing the information in completed KYC forms, UP-X commits to

1. establishing the identity of our counterparties;
2. verify identity, age and location of our players;
3. checking that our counterparties are not considered high-risk (this means checking whether counterparties are based in FATF high-risk jurisdictions, named on government sponsored watchlists or international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRAs));
4. maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses;
5. maintaining KYC records for at least five years;
6. maintaining records of all single or linked cash (or cash-like) transactions above 10,000 EUR;
7. monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.

When registering, it is required to pass a mandatory account verification and provide government documents confirming the user's identity (passport, national ID or driver's license). We also might require proof of address such as a recent utility bill, bank statement, or government correspondence showing the player’s name and address (typically no older than 3 months). In addition to above we may request documentation related to the payment method used for deposits.

We strictly enforce an age restriction on our platform. Players must be at least the legal age in their jurisdiction to participate in gambling activities. As part of the KYC process, players may be asked to provide additional age verification documents if there is any doubt regarding their age.

If we suspect the legitimacy of the user's actions, we ask our users to provide a photo of the user against the background of an identity document (passport, driver's license), as well as documents confirming that the funds really belong to the account in question (bank statement etc.).

Copies of the requested documents must be provided by the user in a readable form by sending to e-mail kyc@up-x.cc

The verification service will review user applications and verify the submitted documents within 72 hours.

We reserve the right to conduct additional verification checks, monitor all transactions for suspicious activity or potential AML concerns, and require players to submit updated documents periodically to maintain compliance with KYC standards.

If counterparties are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:

1. Cease trading with the counterparty
2. Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watchlists or sanctions list
3. Make an on-site visit to the high-risk counterparty.

Failure to complete the KYC process, provide accurate information, or cooperate with requested verifications may result in:

1. Account suspension until the verification is completed.
2. Withholding of funds until identity is confirmed.
3. Permanent account closure in cases of fraudulent activity or non-compliance with legal requirements.