KYC/AML Policy and Procedure

Sage Shark Limitada

Platform: mint.io

Last Update: 13th March 2026


1. Introduction

These are the Know Your Customer (KYC) and Anti-Money Laundering (AML) / Counter-Terrorism Financing (CTF) rules and policy for Mint (“Mint”, “We”, “Us”, or “Our”). It is important that you (the “User”, “You”, or “Your”) read and understand this Policy before accessing or using Our Services.

Mint.io is a next-generation entertainment and iGaming platform that combines engaging games, challenges, interactive features, progression systems, and tokenized rewards for entertainment and user experience purposes (“Services”). By accessing or using Mint.io — including the website, any associated applications, features, reward mechanisms, or related tools — You agree to be bound by this KYC/AML Policy and enter into a legally binding agreement with Us (Mint or its affiliates).

Mint is an independent third-party provider and is not affiliated with, endorsed by, or operated by any external messaging, blockchain, or infrastructure platforms unless explicitly stated. We adopt a risk-based approach to user verification, monitoring, and compliance in line with international best practices and applicable laws. This helps prevent fraud, identity misuse, unauthorized access, and any form of illegal activity.


2. Scope

This policy applies to all clients and users of the Services on Mint. The company reserves the right to request any KYC or additional documentation at any time to verify identity, location, source of funds, or risk profile. Access to services, payments, or withdrawals may be restricted until verification is complete.


3. Risk-Based Approach

Mint adopts a risk-based approach with three levels of due diligence:

  • Simplified Due Diligence (SDD): Low-risk, below-threshold transactions with minimal risk.
  • Customer Due Diligence (CDD): Standard verification for most cases.
  • Enhanced Due Diligence (EDD): Applied to high-risk scenarios, including:
  • Politically Exposed Persons (PEPs), their immediate family, or close associates
  • Customers from high-risk jurisdictions (FATF grey/black lists or internal assessment)
  • High-value activity (e.g., aggregate deposits/withdrawals > USD 20,000 annually)
  • Unusual patterns, cryptocurrency involvement, or high-risk payment methods
  • Adverse media findings

EDD includes source of funds/wealth verification, adverse media checks, and senior management approval.


4. KYC Process

Full KYC is required before withdrawals or when aggregate deposits reach USD 10,000, or if flagged as suspicious:

  • Proof of Identity
  • Government-issued photo ID (passport, driver's license; front/back if required).
  • Criteria: Signature present; non-restricted country; name match; valid (not expiring <3 months); age >18.
  • Proof of Residence
  • Utility bill or bank statement (≤3 months old).
  • Criteria: Non-restricted country; name match with ID.
  • Selfie with ID
  • User holding the submitted ID; matching photo and number.
  • Source of Funds / Source of Wealth (for EDD/high-risk)
  • Documentation (e.g., bank statements, payslips, tax returns, asset proofs) to verify legitimate origins.

5. Restricted Countries

No acceptance from: Austria, France (and territories), Germany, Netherlands (and territories), Spain, Union of Comoros, United Kingdom, USA (and territories), Portugal, all FATF blacklisted countries, or others prohibited by AOFA. GEO IP blocking enforced.


6. Procedure for Unsuccessful KYC Verification

Rejection documented; support ticket created and communicated to user with explanation. Full access restored only after satisfactory verification.


7. Ongoing Monitoring and Sanctions Screening

Ongoing monitoring includes profile reviews and transaction pattern analysis. All customers screened against sanctions lists (OFAC, UN, EU, UK HMT, etc.) at onboarding, key transactions, and periodically (automated where possible). Matches trigger immediate freeze, review, and reporting to AOFA/authorities.


8. Record Keeping

KYC, verification, transactions, and tickets retained ≥5 years (or longer if required). Records confidential, securely stored, and compliant with data protection laws (linked to Privacy Policy).


9. Reporting Obligations

Suspicious activities reported to authorities per law. MLRO (senior appointee) reports to AOFA. Beneficial ownership changes ≥5% notified within 7 business days. Mint maintains up-to-date beneficial ownership register available to AOFA on request. Notify AOFA of license suspensions, material changes, or serious incidents (within 3 working days where applicable).


10. Training and Awareness

Regular staff training on AML/KYC/CTF, suspicious transaction identification, internal reporting, and customer handling. Includes periodic internal audits of AML program effectiveness.


11. AML Compliance Procedures

  • Suspicious Transactions: Flag unusual patterns, large inconsistent sums, restricted jurisdiction activity.
  • Internal Reporting: SARs to MLRO for evaluation/escalation.
  • Player Verification: ID + utility bill before payouts or at USD 10,000 aggregate deposits.
  • Customer Interaction: Identify at-risk gamblers; provide support resources.
  • Cash Transactions: Prohibited; all via secure, traceable methods.
  • Cryptocurrency: Blockchain analysis for high-risk wallets/mixing; full KYC prior; enhanced monitoring for layering.
  • Prohibited Behaviors: No proxy gambling, third-party accounts, or structuring to evade thresholds; violations lead to suspension/closure.

12. Advertising and Marketing Compliance

Advertisements must not discredit Anjouan or target under-age persons. No promotion to prohibited countries; GEO IP blocking enforced.


13. Arbitration and Dispute Resolution

Participate in arbitration per Anjouan Licensing Services Inc. for unresolved disputes.


14. Financial Ratio Requirements

Satisfy ratios as notified by AOFA.


15. Compliance Officer and Key Person

Senior appointee as Compliance Officer/Key Person; regular reporting to AOFA on compliance matters.


16. Summary of Anjouan License Conditions

As part of the licensing framework established by the Online Gaming Act, 2005 of the  Autonomous Island of Anjouan, Sage Shark Limitada must comply with the following key  conditions relevant to AML and general compliance operations: 


  • Jurisdictional Restrictions & GEO IP Blocking: 

- Mint must not market or offer services to residents of prohibited countries,  including but not limited to: Australia, Austria, Comoros, France, Germany, Netherlands,  Spain, United Kingdom, USA, all FATF blacklisted countries, and any others deemed  restricted by the Anjouan Offshore Financial Authority. 

- GEO IP blocking of the above jurisdictions must be implemented. 


  • AML & Player Due Diligence Requirements: 

- Mint must prevent its services from being used for money laundering and  comply with all AML procedures including: 

- Collecting valid government photo ID and a recent utility bill before processing payouts or  upon reaching a deposit threshold of USD 10,000. 

- Monitoring and reporting suspicious transactions, maintaining records, and ensuring  internal reporting processes. 

- Appointing a Money Laundering Reporting Officer (MLRO) to report to the Anjouan  Authority.


  • Responsible Gambling Measures:

- Systems must identify at-risk players and provide access to support services. 


  • Operational & Data Compliance: 

- No cash transactions allowed for player accounts. 

- Weekly data replication to Anjouan servers must be performed using authorized tools. - The Anjouan compliance seal must be visible site-wide. 


  • Reporting & Notification Obligations: 

- Regular reports must be submitted to the Anjouan Authority. 

- Notify the Authority of ownership changes (≥5%) within 7 business days, license  suspensions, serious incidents (within 3 working days), and material changes in submitted  information. 


  • Compliance Oversight: 

- A Key Person/Compliance Officer must report regularly to the Anjouan Authority. - Participate in arbitration where player disputes are unresolved. 

- Use only approved systems providers deemed “fit and proper”. 


  • License Continuity:

- License renewal must be timely with fee payments to avoid suspension or termination


17. Review of Policy

Reviewed annually (or sooner for regulatory/industry changes) to ensure ongoing compliance.


18. Compliance with Anjouan Offshore Authority

Full adherence to AOFA requirements, including reports, meetings, and AML alignment.


19. Third-Party Service Providers and Outsourcing

Where outsourced (e.g., KYC screening, monitoring), providers vetted as fit/proper. Mint retains full responsibility; contracts ensure data protection, audit rights, and AOFA compliance.


20. Version Control and Amendments

v1.0 – 13/05/2025 – Original

v2.0 – 23/02/2026 – Added sanctions screening, PEPs/EDD triggers, SOF/SOW, crypto controls, third-party rules, internal audits, prohibited behaviors, beneficial ownership register.