AML and Sanctions Compliance Policy

1. Policy Purpose

Lynx Gaming Systems and its affiliates, owners, officers, directors, employees, contractors, and service providers (collectively, "Lynx Parties") maintain a risk-based compliance program designed to identify, review, escalate, restrict, reject, suspend, and, where required or appropriate, report suspicious or prohibited activity.

This program is intended to reduce the risk that the Services are used for money laundering, terrorist financing, sanctions evasion, fraud, theft, collusive gameplay, structured activity, or other unlawful conduct.

2. Scope

This Policy applies to all Lynx users, accounts, wallets, funding sources, supported withdrawal destinations, and transactions or value movements connected to Lynx, whether conducted through the website, game interfaces, APIs, smart contracts, or support channels.

3. Customer, Wallet, and Source-of-Funds Review

Lynx may require information or documentation to verify identity, age, jurisdiction, beneficial ownership, wallet control, source of funds, source of wealth, or the purpose of account activity. Lynx may require a user to prove control of a wallet by signature, message verification, test transaction, or another reasonable method.

4. Ongoing Monitoring

Lynx may monitor deposits, funding patterns, off-chain credits and debits, gameplay-linked movement of value, linked-wallet changes, withdrawal patterns, account cycling, referral abuse, collusive gameplay, intentional-loss patterns, structured activity, VPN or proxy usage, and other indicators of elevated fraud, AML, sanctions, or gameplay-integrity risk. Monitoring may be automated, manual, or both.

5. Restricted Activity

You may not use Lynx to:

• disguise source of funds or evade sanctions or AML controls;
• use mixers or concealment tools where Lynx cannot clear the risk;
• create or control multiple accounts to move value improperly;
• engage in collusive gameplay or chip-dumping style conduct;
• misrepresent wallet ownership, identity, jurisdiction, or beneficial ownership; or
• attempt to bypass destination-wallet, source-of-funds, or gameplay-integrity controls.

6. Withdrawal Controls

Lynx may hold, delay, queue, limit, or reject any Supported Withdrawal pending wallet verification, original funding-source review, linked-wallet review, source-of-funds review, sanctions screening, fraud review, gameplay-integrity review, ledger reconciliation, reserve validation, or other legal and operational controls. Lynx may require that a Supported Withdrawal be sent only to a wallet or destination that Lynx has linked, verified, and approved under your account.

7. Geolocation and Sanctions Controls

Lynx may use geolocation tools, IP analysis, VPN or proxy detection, sanctions-list screening, blockchain analytics, customer-identification procedures, transaction monitoring, and risk-based re-screening to prevent prohibited activity and enforce regional restrictions.

8. Enhanced Due Diligence

Lynx may apply enhanced review to higher-risk activity, including larger-value transactions, unusual wallet history, rapid funding-and-withdrawal patterns, abnormal gameplay-linked movement of value, sanctions indicators, or other activity Lynx reasonably considers high risk. Enhanced review may include additional identification checks, source-of-funds requests, wallet tracing, transaction explanations, proof of control, video verification, or other reasonable measures.

9. Investigations, Holds, and Reporting

Lynx may investigate suspicious or prohibited activity, preserve records, restrict features, freeze or limit account functionality, reject transactions, cancel pending Supported Withdrawals, suspend accounts, or terminate access. Lynx may cooperate with regulators, law enforcement, courts, payment partners, compliance providers, and other competent authorities, and may file reports, disclosures, or notices as required or appropriate. Lynx may be prohibited by law from disclosing the existence, status, or outcome of certain reviews, reports, or investigations.

10. Recordkeeping

Lynx may retain compliance records, wallet-screening results, transaction histories, support communications, signatures, verification materials, and internal review records for the period required by law, regulation, partner requirements, internal controls, or ongoing investigation needs.

11. Third-Party Service Providers

Lynx may use third-party compliance, analytics, sanctions-screening, wallet-screening, hosting, identity-verification, treasury, or security providers to support its AML and sanctions program.

12. No Circumvention

You may not take any action intended to bypass Lynx's controls, including by splitting activity across accounts or wallets, using nominees, misdescribing transactions, hiding wallet ownership, or routing through intermediaries to disguise source, destination, or beneficial ownership.

13. Changes to This Policy

Lynx may update this Policy as legal requirements, risk exposure, supported assets, supported networks, or operational controls evolve. Continued use of the service after the effective date of an updated Policy constitutes acceptance to the extent permitted by law.

14. Contact

For compliance questions, contact Lynx Gaming Systems and its affiliates at: support@lynx.house