AML/KYC

Money Laundering and the Fight Against It

Money laundering (ML) is the process of legitimizing funds obtained through criminal means as a result of illegal drug trafficking, terrorism, and other illicit activities. Criminals attempt to launder money by disguising the source and/or changing the form of the funds or moving them to a place where they are less likely to attract attention.

The fight against money laundering (AML) is a financial and legal term that describes the legal control measures that require financial institutions and other regulated organizations to prevent and detect ML-related activities and to report them.

An effective AML program requires a jurisdiction to:

• Provide relevant regulators and police with the authority and tools to investigate ML cases.
• Require financial institutions to identify their clients, conduct risk-based controls, keep records, and report suspicious activity.
• Ensure the ability to exchange information with other jurisdictions, depending on the circumstances.

Regulation

Employees working in the remote gambling industry are required to report information that comes to them in the course of their activities:

• When they know something;
• When they suspect something;
• When they have reasonable grounds to know or suspect that a person is involved in money laundering, financing terrorism, or spending criminally obtained money.

This is collectively referred to as actual knowledge or reasonable suspicion. Authorities require us to demonstrate (and prove) that risk assessment was conducted and carried out before entering into business relationships with clients and that a comprehensive legal examination of client transactions corresponds to the level of associated risk.

The seller must be able to demonstrate that the extent of ongoing monitoring corresponds to the level of risk and that all records are kept by us with proper risk profile control. In this document, we have described additional measures for risk monitoring, as well as justified the need for clients to declare the source of funds in situations that present a high risk and may indicate money laundering.

Special Regulations

The seller must ensure compliance with the requirements for all aspects of our business and have a Curacao Gaming License, allowing them to operate in the international gambling market through service lines.

Crime, Violations, and AML Policy

The anti-money laundering (AML) policy includes a series of principles and practical approaches:

• Development of control systems and measures that correspond to the specifics of our business and legislative requirements.
• Annual assessment of risks associated with AML and the application of adaptive and economically justified response methods.
• Responsibility for the implementation of the AML policy, which lies with all employees, including management.
• Regular review and evaluation of the effectiveness of the measures taken.
• Maintenance of documentation for transactions in accordance with requirements for conducting investigations into money laundering and financing of terrorism.
• Providing training for employees involved in processes related to AML.
• Providing designated employees with the necessary resources and autonomy for independent work.

Risk Management

Our company employs risk assessment and management strategies to effectively counteract money laundering and terrorism financing:

• Identification of risks associated with money laundering and terrorism financing, specific to our activities.
• Development and implementation of targeted policies and procedures to minimize and manage these risks.
• Constant monitoring and improvement of the effectiveness of control measures.
• Documentation of actions taken and justification of decisions made.

We focus our efforts on the most significant aspects to ensure maximum protection. Our risk management policy is fully supported by management and staff and is regularly reviewed to comply with current conditions and requirements.

Suspicious Activity and Its Handling

Identifying and responding to suspicious activity is important for securing transactions. We apply measures for user verification, including:

1. Checking documents that verify identity.
2. Analysis of utility bills.
3. Analysis of bank statements.
4. Other methods of identity confirmation.

Special attention is given to players with unusual deposit patterns. We conduct thorough checks if we detect signs of suspicious activity.

Reports of Suspicious Activity

All employees are required to report any suspicions of activity related to money laundering or terrorism financing. Unauthorized disclosure of information or its concealment carries legal consequences. Reports of suspicious activity must be made confidentially.

Work Procedures

We closely monitor transactions and player activity to identify anomalies. Before approving fund withdrawals, we verify the deposit history to ensure its legality and compliance with the client’s usual behavior.

Withdrawal Procedure

Before carrying out a withdrawal operation, we ensure that the client’s actions correspond to their usual bets and transactions. Funds are returned via the same payment method that was used for the deposit.

Monitoring Process

We adhere to strict AML rules, actively monitor, and respond to any suspicions. The impermissibility of ignoring indicators of suspicious activity ensures compliance with legislative requirements and protects our business from potential threats.

Accounting and Control

In accordance with our obligations, we ensure the maintenance and support of an audit log to facilitate financial investigations. Our accounting system includes:

• Documentation and control of compliance with regulatory requirements by designated personnel.
• Distribution of responsibilities for combating money laundering and terrorism financing among specialized employees.
• Recording cases when an employee did not take measures, with reasons specified.
• Registration of customer identification and verification procedures.
• Accounting for all significant business relationships and transactions.
• Records of employee training programs in the field of AML/CFT.
• Preparation and transfer of reports on suspicious activity to the appropriate structures.
• Interaction with law enforcement and national bodies on AML matters.

Thus, we ensure transparency and compliance of our actions with all requirements related to the prevention of financial crimes.

Violations and Consequences

We inform all employees about the legal consequences in the event of violating the following laws:

• Failing to report information about suspicious activity, which violates the laws on criminal proceeds and anti-terrorism legislation.
• Criminal liability for employees who fail to disclose suspicious information properly or in a timely manner.
• Legislative violations related to disclosing the fact of conducting or the possibility of conducting an investigation into money laundering or terrorism.
• Violations related to forgery, concealment, destruction, or improper handling of documents related to the investigation.

Our employees are aware of the seriousness of these violations and possible criminal consequences, emphasizing the importance of complying with legislation and internal company rules.

Compliance with Fraud Prevention and Data Protection Norms

The Seller’s policy strictly prohibits any fraudulent actions, and upon detection, the client’s account is subject to immediate blocking. Regarding data protection, we use the Payment IQ service for encrypting and storing all customer payment data, ensuring that employees do not have access to sensitive information. The company implements extensive security measures to protect customer information, including authentication systems, password policies, protection against malware, intrusion prevention measures, and effective network security management.

Internal Accounting and Reporting

We adhere to the principles of “Know Your Customer”, maintain meticulous internal accounting, and ensure that all operations comply with legislation. All data on transactions and client actions, as well as records of investigations and reports of suspicious activity, are stored for six years after the account’s activity ends or the investigation is completed.

Know Your Customer (KYC)

By accepting our Terms, you consent to all necessary checks to confirm your identity and contact information, which may be required by us or third parties, including regulatory bodies. During these checks, access to withdrawing funds from your account may be restricted.

False or incomplete information may lead to the immediate blocking of your account and exclusion from using our services. If your adult status cannot be confirmed, your account will be temporarily frozen. Minors who have conducted transactions will be prohibited from using the account, all operations will be canceled, and winnings confiscated.

Please immediately notify our support service of any changes in your personal data.