Effective Date: April 2026
Jurisdiction: Autonomous Island of Anjouan, Union of the Comoros
IOGr B.V. (“Company”, “we”, “our” or “us”) operates the website https://donbaba.ng/, including all associated subdomains, tools, and services (collectively, the “Website”).
As a leading platform for the Chicken Road gaming experience in Nigeria, we are committed to the highest standards of transparency and integrity. This KYC (Know Your Customer) & AML (Anti-Money Laundering) Policy explains how we identify, verify, and monitor our B2B clients and partners to ensure compliance with global regulatory standards and to prevent the misuse of our services for illicit activities.
1. Purpose and Scope
This Policy sets forth our internal procedures designed to mitigate risks such as money laundering, terrorist financing, and other criminal activities. It applies to all B2B partners—including casino operators, resellers, service integrators, and other corporate entities—engaging with the Company to provide the Chicken Road game to the Nigerian market.
2. Risk-Based Approach (RBA)
We do not believe in a “one size fits all” strategy. We follow a structured risk-based framework during client onboarding. Client risk profiles are assessed based on:
- Jurisdiction of operation.
- Ownership structure.
- Business model and market reputation.
Based on this assessment, partners are assigned either Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD). These profiles are reviewed annually to ensure the safety of the Nigerian gaming ecosystem.
3. Due Diligence Requirements
3.1 Customer Due Diligence (CDD)
Standard partners are required to provide the following documentation (dated within the last 3 months):
- Corporate Documents: Certificate of Incorporation or Trade Register Extract.
- Constitutional Documents: Articles or Memorandum of Association.
- Proof of Business Address: Recent utility bill or bank statement.
- Ownership Transparency: A corporate structure chart identifying all Ultimate Beneficial Owners (UBOs) with more than 25% ownership.
- Identity Verification: Government-issued photo ID (Passport or National ID) and proof of residence for all directors and UBOs.
3.2 Enhanced Due Diligence (EDD)
Enhanced scrutiny is applied to partners falling under high-risk categories, such as those operating from FATF-listed jurisdictions or those with complex offshore holdings. Additional requirements may include:
- Evidence of Source of Funds (SoF) or Source of Wealth (SoW).
- Third-party AML audit reports.
- Verification of valid gaming licenses.
- In-depth reputational background checks.
4. Ongoing Monitoring
Our commitment to safety doesn’t end at onboarding. We periodically review our B2B partners to ensure their status remains “correct.” If we detect suspicious activity or a significant change in ownership, we reserve the right to temporarily suspend services pending a full investigation. Partners are expected to notify us immediately of any structural or legal changes.
5. PEP and Sanctions Screening
To protect our platform and Nigerian players, all directors and UBOs undergo rigorous screening against global sanctions lists and Politically Exposed Person (PEP) watchlists (including UN, EU, OFAC, and Refinitiv). Matches may result in immediate rejection or heightened scrutiny.
6. Recordkeeping
In accordance with Anjouan AML regulations, all digital and physical KYC/AML documentation is retained for a minimum of six (6) years following the termination of a business relationship. This ensures a transparent trail for regulatory audits.
7. Restricted Jurisdictions
Chicken Road Nigeria (via IOGr B.V.) does not onboard clients from:
- FATF high-risk or non-cooperative jurisdictions.
- Countries currently under UN, EU, or OFAC sanctions.
- The Union of the Comoros (for white-label services targeting that specific jurisdiction).
- Other territories restricted by the Anjouan Offshore Financial Authority.
8. Failure to Comply
We take compliance seriously. Failure to provide accurate, up-to-date, or timely KYC documentation will result in:
- Rejection of the onboarding request.
- Immediate suspension of current services.
- Termination of the business relationship.
- Potential reporting to the relevant regulatory authorities.
9. Amendments
As the legal landscape in Nigeria and internationally evolves, we reserve the right to modify this Policy. We will communicate material changes to our partners in advance to ensure continued compliance and a safe “road” for all.
For questions regarding our compliance procedures, please contact us through our official Contact Page.