Coin Mixing Policy

Coin Mixing & Wagering Requirements Policy

1. Purpose & Scope

This Policy sets out Betida’s controls relating to the use of coin-mixing or anonymity-enhancing techniques and the wagering requirement applied to deposits for Anti-Money Laundering (AML) compliance.

It applies to all customers and all supported assets.

2. Key Definitions

• Coin Mixing / Tumbling / CoinJoin:
  Services or techniques designed to obfuscate the origin or ownership of crypto funds.
• Anonymity-Enhancing Cryptocurrencies (AEC):
  Assets or features intended to conceal sender, receiver, or transaction amounts.
• High-Risk Address / Exposure:
  Addresses, UTXOs, clusters, or flows flagged by blockchain analytics as linked to mixers, illicit activity, or sanctioned entities.

3. Wagering Requirement (1×)

To withdraw or tip funds, you must wager at least an amount equal to 1× (one times) the total value of your most recent deposit(s).

This requirement ensures that deposits are used for gameplay rather than payment transfer or layering.

Notes:

• Wagering applies before each withdrawal request is approved.
• Bonus funds are subject to separate promotion terms and do not reduce the 1× requirement unless expressly stated.
• We may exclude zero/low-risk or hedged bet patterns from counting toward wagering at our reasonable discretion.

4. Prohibited or Restricted Activity

You must not:

• Deposit from, withdraw to, or otherwise route funds through mixers/tumblers/CoinJoin services.
• Use AEC features or privacy add-ons to conceal the source or ownership of funds.
• Attempt to circumvent AML monitoring, including peel chains or cross-chain obfuscation designed to disguise provenance.

Where high-risk exposure is detected (e.g., mixer adjacency, sanctioned links, or illicit typologies), we may apply the controls below.

5. Monitoring & Controls

We use blockchain analytics and internal rules to screen deposits, withdrawals, and addresses for risk indicators.

If risk is identified, we may:

1. Place a temporary hold;
2. Request additional KYC/EDD and proof of source of funds;
3. Decline a transaction; and/or
4. Close the account where required by law or licence conditions.

6. Withdrawals, Holds & Forfeiture

Withdrawals may be delayed or declined until the 1× wagering requirement is met and any AML reviews are completed.

Where prohibited activity is confirmed or reasonable suspicion persists, we may:

• Void promotions,
• Withhold withdrawals, and
• Close related accounts in accordance with applicable law and our Terms & Conditions.

7. Appeals & Support

If you believe we have made a mistake or need assistance, contact [email protected] from your registered email address.

Provide any requested information (e.g., transaction evidence) to help us review promptly.

8. Reporting & Record-Keeping

We maintain AML records and, where required, file reports with competent authorities.

Information may be shared with regulators or law enforcement in accordance with legal obligations.

9. Approval & Sign-off

To be completed post-incorporation.