AML/KYC Policy

Anti-Money Laundering & Know Your Customer — Last updated: 8 April 2026

1. Introduction

NextFrameBase is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This policy describes the measures we take to prevent money laundering, terrorism financing and other financial crimes through our Platform.

We operate in compliance with the following Australian legislation and regulatory frameworks:

• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
• Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007
• Financial Transaction Reports Act 1988
• Guidelines and directives issued by the Australian Transaction Reports and Analysis Centre (AUSTRAC)

2. AUSTRAC Compliance

NextFrameBase is registered with AUSTRAC as a reporting entity. We are required to:

• Identify, manage and mitigate money laundering and terrorism financing (ML/TF) risks.
• Maintain an AML/CTF compliance programme approved by senior management.
• Conduct Customer Due Diligence (CDD) and ongoing monitoring.
• Submit reports to AUSTRAC as required by law.
• Maintain records for a minimum of 7 years.
• Provide AML/CTF training to all relevant staff.

3. Know Your Customer (KYC)

3.1 Customer Identification

Before you can deposit, withdraw funds, or participate in games on NextFrameBase, you must complete our identity verification process. This involves providing:

• Full legal name as it appears on your government-issued identification.
• Date of birth — you must be at least 18 years old.
• Residential address — a current Australian residential address.
• Government-issued photo identification — at least one of the following:
  • Australian driver's licence
  • Australian passport
  • Australian proof-of-age card
  • Foreign passport (for non-Australian residents where permitted)
• Proof of address — a recent utility bill, bank statement, or government correspondence (issued within the last 3 months).

3.2 Electronic Verification

We use electronic identity verification services to verify your details against trusted government and commercial data sources. In most cases, this process is completed within minutes. If electronic verification is not possible, we will require you to upload physical documents.

3.3 Enhanced Due Diligence (EDD)

In certain circumstances, we may conduct Enhanced Due Diligence, which involves additional verification steps. EDD may be triggered when:

• A customer is identified as a Politically Exposed Person (PEP) or a close associate of a PEP.
• A customer is from or transacts with a high-risk jurisdiction as identified by the Financial Action Task Force (FATF).
• Unusual or suspicious transaction patterns are detected.
• The customer's identity cannot be satisfactorily verified through standard CDD.
• Large or unusual transactions exceed defined thresholds.

EDD may include requests for:

• Source of funds documentation (e.g., payslips, tax returns, bank statements).
• Source of wealth information.
• Additional identification documents.
• Face-to-face or video verification.

4. Ongoing Monitoring

We continuously monitor customer activity to detect and report suspicious behaviour. Our monitoring programme includes:

• Transaction monitoring: Automated systems analyse all transactions for unusual patterns, including rapid or large deposits, structuring (splitting transactions to avoid thresholds), and inconsistencies between stated income and transaction volumes.
• Behavioural monitoring: Analysis of account activity, login patterns and gameplay behaviour to identify anomalies.
• Sanctions screening: Regular screening of customers against Australian and international sanctions lists, including DFAT, UN, EU and OFAC lists.
• PEP screening: Identification and ongoing monitoring of Politically Exposed Persons.
• Periodic review: Regular review and update of customer risk profiles.

5. Suspicious Activity Reporting

NextFrameBase is legally obligated to report suspicious matters to AUSTRAC. A Suspicious Matter Report (SMR) will be filed when we have reasonable grounds to suspect that:

• A transaction or activity may be related to money laundering or terrorism financing.
• A customer has provided false or misleading identification information.
• A transaction has no apparent lawful purpose.
• A customer is structuring transactions to avoid reporting thresholds.

We are also required to submit Threshold Transaction Reports (TTRs) for cash transactions of $10,000 AUD or more, and International Funds Transfer Instruction (IFTI) reports for international transfers.

6. Record Keeping

In accordance with the AML/CTF Act, we maintain records of:

• Customer identification and verification documents — retained for 7 years after the end of the customer relationship.
• Transaction records — retained for 7 years from the date of the transaction.
• Suspicious matter reports and supporting documentation — retained for 7 years from the date the report was made.
• AML/CTF programme documentation and training records.

7. Staff Training

All NextFrameBase employees and contractors who handle customer data, process transactions, or perform compliance functions receive comprehensive AML/CTF training, including:

• Initial training upon commencement of employment.
• Annual refresher training on AML/CTF obligations and emerging risks.
• Specific training on identifying red flags and suspicious activity indicators.
• Training on internal reporting procedures and escalation pathways.

8. Consequences of Non-Compliance

If you fail to complete KYC verification, provide false information, or are found to be involved in money laundering or other financial crimes:

• Your account may be suspended or permanently closed.
• Funds may be frozen pending investigation.
• The matter may be reported to AUSTRAC, law enforcement and other relevant authorities.
• Any winnings derived from fraudulent or criminal activity will be forfeited.

9. Your Obligations

As a user of NextFrameBase, you agree to:

• Provide accurate and truthful identification information.
• Promptly update your information if any details change.
• Cooperate fully with any verification requests.
• Not use the Platform for money laundering, terrorism financing or any other illegal purpose.
• Not allow any third party to use your account.

10. Contact

For questions about our AML/KYC procedures or to report suspicious activity, please contact our Compliance Team: