KYC Policy

Last updated: 13.07.2025

The Company strictly adheres to and complies with the Know Your Customer (KYC) principles, which are designed to prevent financial crime and money laundering through comprehensive customer identification and due diligence. At any time, the Company reserves the right to request any KYC documents it deems necessary to determine the identity and location of a user on the pavilion88 website (the “Website”). We reserve the right to restrict access to services, payouts, or withdrawals until the user's identity has been sufficiently established, or for any other reason deemed necessary within the framework of legal regulations.

We employ a risk-based approach, performing strict due diligence checks and ongoing monitoring of all clients, customers, and their transactions. In accordance with anti-money laundering regulations, we utilize three stages of due diligence, depending on the assessed risk, transaction size, and customer type:

  • SDD (Simplified Due Diligence): Used in instances of extremely low-risk transactions that do not meet the required thresholds.
  • CDD (Customer Due Diligence): The standard level of due diligence, used in most cases for verification and identification.
  • EDD (Enhanced Due Diligence): Applied to high-risk customers, large transactions, or other special cases requiring a more thorough review.

Furthermore, when a user's aggregate lifetime deposits exceed MYR 10,000, when a withdrawal of any amount is requested, or when a transaction is deemed suspicious, the user is required to complete the full KYC process.

During the full KYC process, the user will need to provide some basic personal details and upload the following documents:

  1. A copy of a Government-Issued Photo ID (front and back may be required depending on the document).
  2. A photo of themselves holding the ID (a "selfie with ID").
  3. A recent bank statement or utility bill as proof of residence.

Guidelines for the "KYC Process"

a. Proof of ID

  • The document must be valid.
  • The issuing country must not be on the restricted countries list below:
    • United States of America and its territories,
    • Austria,
    • France and its territories,
    • Netherlands and its territories and countries that form the Kingdom of Netherlands, including Bonaire, Sint Eustatius, Saba, Aruba, Curaçao, and Sint Maarten,
    • Australia and its territories,
    • United Kingdom of Great Britain and Northern Ireland,
    • Spain,
    • Cyprus,
    • Afghanistan,
    • American Samoa,
    • Barbados,
    • Botswana,
    • Burundi,
    • Cambodia,
    • Central African Republic,
    • Cuba,
    • Democratic People’s Republic of Korea (DPRK) or North Korea,
    • Democratic Republic of Congo,
    • Guam,
    • Iran,
    • Iraq,
    • Lebanon,
    • Libya,
    • Mali,
    • Myanmar (Burma),
    • Nicaragua,
    • Pakistan,
    • Palau,
    • Palestine,
    • Samoa,
    • Somalia,
    • South Sudan,
    • Sudan,
    • Syria,
    • The Crimea Region (Russia/Ukraine),
    • Trinidad and Tobago,
    • Uganda,
    • Union of Comoros,
    • Venezuela,
    • Yemen,
    • Zimbabwe,
    • North Macedonia,
    • Any other jurisdictions deemed prohibited by the Anjouan Offshore Financial Authority and designated as high-risk in accordance with applicable Malaysian AML/CFT guidelines.
  • The full name on the document must match the client’s registered name.
  • The document must be valid for at least 3 more months.
  • The owner must be over 18 years of age.

b. Proof of Residence

  • A bank statement or utility bill.
  • The country of residence must not be on the restricted countries list below:
    • Austria,
    • France and its territories,
    • Germany,
    • Netherlands and its territories,
    • Spain,
    • Union of Comoros,
    • United Kingdom,
    • USA and its territories,
    • All FATF Blacklisted countries,
    • Any other jurisdictions deemed prohibited by the Anjouan Offshore Financial Authority and designated as high-risk in accordance with applicable Malaysian AML/CFT guidelines.
  • The full name and address must match the client’s registered name and be identical to the information on their ID.
  • The document must have been issued within the last 3 months.

c. Selfie with ID

  • The person in the selfie must clearly be the same person shown on the Proof of ID document.
  • The ID held in the selfie must be the exact same document submitted as "Proof of ID," and all details must be clearly visible.

Notes on the "KYC Process"

If the KYC process is unsuccessful, the reason will be documented, and a support ticket will be created. The user will then be notified with the ticket number and an explanation of the issue. The account will be approved once all required documents have been successfully submitted and verified.