Anti-Money Laundering (AML) and Know-Your-Customer (KYC) Policy

1. Purpose and legal basis

This Anti-Money Laundering and Know-Your-Customer Policy (“AML/KYC Policy”) describes the measures implemented by NAVRATILOVA LIMITED (Company Registration No. 15176878, registered office: B1 Vantage Park Old Gloucester Road, Hambrook, Bristol, United Kingdom, BS16 1GW) to prevent money laundering, terrorist financing, fraud, and misuse of its services.

This Policy is established in accordance with applicable United Kingdom legislation, including the Data Protection Act 2018, the UK GDPR, and relevant AML/CFT regulatory requirements, and is designed to operate alongside the Company’s Privacy Policy.

2. Scope of application

This AML/KYC Policy applies to:

• Partners, affiliates, and other users participating in referral or partner programs;
• Any individual or legal entity eligible to receive payouts or commissions from the Company;
• All financial transactions related to partner rewards, commissions, or similar compensation.

3. Risk-based compliance approach

NAVRATILOVA LIMITED applies a risk-based approach to AML and KYC compliance.
The nature, frequency, and depth of verification and monitoring measures depend on factors such as:

• Transaction volume and payout frequency;
• Chosen payment method;
• Behavioural patterns, traffic quality, and conversion activity;
• Geographic and operational risk indicators.

4. KYC verification requirements

4.1 When verification is required

KYC verification is completed prior to any payout and before referral tools are activated. Additional verification steps may be introduced at any time — for example, following a significant change in transaction patterns, detection of atypical activity, or when required by regulatory obligations, payment partners, or internal compliance procedures. Periodic re-verification may also apply depending on risk level.

4.2 Data collected for verification

For AML/KYC purposes, the Company collects only information reasonably necessary to confirm identity and payout eligibility, which may include:

• A valid government-issued identification document;
• Proof of residential address issued within the last three (3) months;

Additional information may be requested strictly where necessary for compliance, fraud prevention, or payment provider requirements.

All personal data collected for AML/KYC purposes is processed in accordance with the Privacy Policy.

4.3 Verification process

The standard verification process includes:

1. Notification to the partner regarding the verification requirement, if applicable
2. Secure submission of requested documents;
3. Review of documents for authenticity, consistency, and completeness;
4. Approval, rejection, or request for additional information.

4.4 Payout ownership and name matching

Payouts may be issued only to payment instruments owned by the verified partner.

The name associated with the bank account or card must exactly match:

• The name provided during KYC verification; and
• The name shown on the submitted identification documents.

Payouts to third-party accounts or cards are strictly prohibited.

4.5 Verification timeframe

KYC/AML verification is usually completed within 24–48 hours after all required documents have been successfully submitted.

In limited cases — including enhanced due diligence, manual review, or additional information requests — verification may take up to 72 hours.

5. Sanctions Screening

5.1 NAVRATILOVA LIMITED maintains a zero-tolerance policy regarding transactions involving individuals, entities, or jurisdictions subject to international sanctions.

5.2 All partners and payout recipients are screened against applicable sanctions lists, including but not limited to:

• The UK Sanctions List (maintained by OFSI);
• The consolidated list of financial sanctions targets in the UK;
• Relevant international lists (e.g., UN, EU, and OFAC) where applicable.

5.3 Screening is conducted at the time of onboarding and on a recurring basis. If a match is identified:

• The account will be immediately frozen;
• All payouts will be suspended;
• A report will be made to OFSI as required by the Sanctions and Anti-Money Laundering Act 2018.

6. Ongoing monitoring

The Company conducts ongoing monitoring of partner activity, which may include:

• Analysis of traffic quality and conversion behaviour;
• Review of transaction patterns and refund ratios;
• Detection of self-purchases, artificial traffic, or manipulation.

Where elevated risk is identified, enhanced due diligence measures may be applied.

7. Fraud prevention and enforcement

Where fraud, abuse, or suspicious activity is suspected or confirmed, NAVRATILOVA LIMITED reserves the right to:

• Suspend or terminate accounts;
• Delay or withhold payouts;
• Adjust or revoke partner status or tiers;
• Terminate contractual relationships.

Where required by law, relevant information may be disclosed to competent authorities.

In accordance with UK law, the Company will submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) where there is knowledge or suspicion of money laundering or terrorist financing. This includes seeking a Defence Against Money Laundering (DAML) for transactions exceeding the £3,000 threshold where criminal property is suspected.

8. Data protection and retention

Personal data collected for AML/KYC purposes is:

• Processed lawfully and transparently;
• Stored securely with restricted access;
• Used solely for compliance, fraud prevention, and legal obligations.

While users may exercise data protection rights under the Privacy Policy, certain AML-related data may be retained where required by applicable law or regulatory obligations, even if a deletion request is submitted.

9. Policy updates

This AML/KYC Policy may be updated from time to time to reflect regulatory changes or improvements to compliance practices.
The latest version is available upon request.

10. Contact information

For AML/KYC-related inquiries, please contact:

Email: [email protected]
Phone: +44 7418 376712