It is the policy of Company to comply in all respects with the requirements of the Money Laundering Legislation by ensuring that we have policies and procedures to aid compliance. The main scope of this policy is to establish the essential standards designed to prevent the Company from being used for money laundering and terrorism financing. This Anti-Money Laundering (AML) policy applies to the Company and all of its staff who provide services which might be used to conceal or disguise the true origins of criminally derived proceeds with the intention to make unlawful proceeds appear to have derived from legitimate origins or to constitute legitimate assets.
2. General Obligations
This Policy sets out the procedures which must be followed to enable the Company to comply with its legal obligations. To give effect to this AML policy, the Company is committed to:
2.1. Formulate and implement internal rules and develop procedures and systems to detect and monitor suspicious transactions and to report thereon to the relevant authorities;
2.2. Ensure sufficient resources are devoted to the training of staff increase their awareness and ability to deal with suspicious transactions and to keep them informed of new legislative developments and requirements;
2.3. Ensure commercial considerations never override the need to comply with the Regulations;
2.4. Create an environment where staff who report on suspicious transactions can do so confidentially and without fear of reprisal.
3. Definition of Money Laundering and Terrorist Financing
Money laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds or any other benefit of their criminal activities, thereby avoiding prosecution, conviction and confiscation of the criminal funds. There are three stages in the process:
a. Placement: Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments.
b. Layering: How the link between the funds and the criminal is concealed.
c. Integration: Investing and/or recovering the funds in a way that looks legitimate.
As it is strictly a Company policy not to accept cash as means of payment, the Company’s AML Policy is focused to prevent the use of the Company’s activities and resources in the 2nd and in the 3rd stage.
4. Money Laundering Reporting Officer (MLRO)
The nominated Money Laundering Reporting Officer (MLRO) shall receive disclosures about any suspected money laundering or financial terrorism activity and shall be responsible for informing the Company of the AML policies and procedures. The responsibilities of the MLRO is to supervise the actions of the Company and consider the contents of any report made to him/her in relation to relevant information that is available to the Company.
5. Prohibited Countries
The company prohibits customers from registering from high risk countries as identified by the Financial Action Task Force, the company may also prohibits customers from registering from countries that do not wish to service.
5.1 Customer due diligence
The company follow a risk-based approach, the appropriate due diligence can be applied to such a customer. This means that the higher the ML/FT risk is, the greater the level of due diligence will therefore, there is a particular emphasis on higher risk customers.
5.2 Customer Simplified Due Diligence
The following information is obtained at onboarding stage
• Full Name
• Residential Address
• Date of Birth
• E-mail address and Mobile Number
• Identity reference number, when available
5.3 Customer Due Diligence
• The Company identifies and performs verification checks on all players, as set out by the Curacao regulations.
• All customers are requested to provide due diligence upon reaching total deposits of withdrawals of 3,000 USD.
• The company terminates the business relationship with the customer when due diligence documentation is not received within 30 days from the initial request. Withdrawals should not be permitted until verification is received and approved.
5.4 Due Diligence
• In order to verify the details on their player account, The company will request the customer to provide a copy of one document from each of the categories listed below:
Personal identification
• Valid Passport
• Valid driving License
• Valid National identification Document (Picture ID)
Where any such document does not allow verification of one’s residential address, the following documents will be requested.
Address verification
• Utility Bill, which is less than 3 months old. Mobile phone bills are not sufficient. The bill provided must pertain to a service delivered to the address provided by the player upon registration
• Tax Bill
• Copy of Bank Statement, which is less than 3 months old
All documents received are vetted by employees and authenticity checks ensure the documentation is genuine and have not been tampered or are fake.
In addition to completing the registration form, the Company may carry out additional verification procedures (such as an ID card or driving licence) before any pay-out. If necessary, the Company will do a phone verification exercise, which will involve calling the number the user has stated and verify the information provided by the player.
Source of Payment Verification
• Player account registered credit or debit card (Front only
• Copy of credit or debit card account statement of card registered with the player account.
• Copy of bank statement, which must have the company’s transaction or the registered card number visible.
Once all the information requested is obtained, the Company sends a confirmation email to the customer on the email inserted by the customer in the registration form
In addition, to the due diligence process performed at initial acceptance stage, the players are monitored on an on-going basis. Internal Controls as per section 8 provide the framework for on-going monitoring of the players.
6. Customer risk assessment
All customers are categorised based on their AML/CFT risk. The following risks factors are assessed:,
• Customer Risk
• Geographical Risk
• Product Risk
• Payment Risk
Customers that are categorised as high risk are requested to provide enhance due diligence.
7. Monitoring of Suspicious Activity
The Company will monitor for suspicious activity. If any such suspicious activity is detected, additional due diligence will be performed before proceeding with the transaction. If a reasonable explanation is not determined, the suspicious activity shall be reported to the MLRO. Suspicious Activity includes but is not limited to:
a. The player exhibits unusual concern regarding the terms and conditions of his/her player account, particularly with respect to his/her identity, or furnishes unusual or suspect identification or business documents.
b. The customer has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations;
c. The player displays unusual activity such as large deposits and withdrawals, or deposits and immediate withdrawals;
d. The player requests winnings to be deposited in another player’s account.
When suspicious activity is detected, the company will request enhanced due diligence documentation from the customer, in addition the member of staff will immediately report the customer to the MLRO.
7.1 Enhanced Due Diligence
The company will request the following enhanced due diligence from customers:
• Payslip or bank statement showing salary being processed
• Annual self-assessment tax return
• Company's financials
• Pension Plans
8. Politically Exposed Person and Sanctions
All customers of the company are checked against PEP database upon reaching total deposits of 2K EUR, all customers identified as a potential PEP, or a sanctioned person will be reviewed by the Risk Team and if verified their account will closed and the MLRO informed.
The company will rescreen customers against these databases as part of on-going monitoring.
9. Adverse Media
All customers are checked for Adverse Media upon reaching total deposits of 3,000 USD, all customers identified as having adverse media will be reviewed by the MLRO, who will decide if source of wealth/funds documents are required.
The company will rescreen customers against these databases as part of on-going monitoring.
10 On-going monitoring
In accordance with Customer Due Diligence measures listed under Article 7 of the Prevention of Money Laundering and Funding Terrorism Regulations of 2003, it is the policy of this Company to undertake a risk assessment, and ensure that evidence of customer’s identity is obtained and retained as appropriate for all clients.
Due to the nature of the online gaming business, the Company conducts an enhanced due diligence process for all of its prospective customers.
Notification to customers
On the Company’s website under “terms and conditions” the Company will provide notice to its customers that it may collect certain customer identification information from each customer as well that it is complies to AML regulations. Refer to abstract below;
“The Company complies with the Prevention of Money Laundering Act and Regulations issued thereunder. The Company shall check all transactions to prevent money laundering. The Company shall report any suspicious transaction to the relevant competent authorities. If You become aware of any suspicious activity relating to any of the Games of the Website, You must report this to the Company immediately. The Company may suspend, block or close Your Member Account and withhold funds if requested to do so in accordance with the Prevention of Money Laundering Act.”
Before registering an account, the Customer will have to agree to these Terms and Conditions.
This evidence will be obtained before the customer can access the online games. In case that the customer is a Politically Exposed Person (PEP), the customer is considered as high risk and further due diligence procedures is performed at the Company’s discretion.
In addition to completing the registration form, the Company may carry out additional verification procedures (such as an ID card or driving licence) for any payout. If necessary, the Company will do a phone verification exercise, which will involve calling the number the user has stated and verify the information provided by the player.
Once all the information requested is obtained, the Company sends a confirmation email to the customer on the email inserted by the customer in the registration form. The player account may be blocked or closed if the requested information or documents, or if such information or documents supplied is/are found false or misleading.
In addition, to the due diligence process performed at initial acceptance stage, the players are monitored on an on-going basis. Internal Controls as per section G provide the framework for on-going monitoring of the players.
11. Internal Controls
Internal control procedures have been designed to comply with the regulations. Internal controls take the form of manual controls implemented on a daily basis by Company’s Operations Team (and/or Payments Team) and computer/automated controls inherent within the gaming system software.
The gaming system has inbuilt internal control tools which based on the information inputted by the prospective customers can trigger red flags about suspicious activity to the Operations Team. Refer to some examples below:
• Prevention of multiple accounts held by same user: Inbuilt system checks confirm whether the email provided by the prospective customer is unique in the customer database preventing the possibility of a player having multiple accounts. If a player tries to open more than one account, for whatever reason, the Company reserves the right to block or close any or all of the player’s accounts at its discretion.
• Detection of any underage registrations: Underage registrations are automatically not allowed by the system;
• No cash and no credit policy: Credit card deposits are accepted by the system only if the customer enters a valid credit card number with sufficient funds. A player can participate in any game only if the player has sufficient funds on his/her Member Account for such participation. It is the Company’s policy not to accept cash and not to give any credit whatsoever for participation in any game;
• Withdrawal is only allowed if the name of person requesting the withdrawal is the same name of person holding the bank account: The Company’s policy is that it shall only affect payout to an account, card, wallet or similar instrument in the name of the player receiving payout. Under no circumstances shall the Company affect a payout to a player in a name other than in the name of the player.
• Prevention of prohibited countries: Inbuilt system blocks customers from logging in their gaming account from countries that are high risk as identified by the business or financial action task force.
Internal controls are not entirely computer dependent. The Operations Team also has an important part in detecting and preventing money laundering. The below are a number of controls operated by the Operations Team:
a. On-going monitoring and assessment of player’s risk indicators and changes in players patterns;
b. On a daily basis a deposits report is reviewed by the payment and risk department and follow ups made on suspicious transactions and manually entered deposits;
c. Monitoring of large deposits and withdrawals and/or deposits and immediate withdrawals;
d. All withdrawals are approved by a member of the Payment Department;
e. The Operations Team confirm that the name of person requesting the withdrawal is the same name of person holding the bank account. Suspicious credit card deposits, transactions and accounts are followed up by a verification process;
f. Customer log activity is regularly analysed for indications of suspicious activity;
g. Operations team also prepares weekly and monthly high level reports for review by top management.
Additional verification on suspicious deposits, transactions or accounts will include but not limited to:
a. Call Player to verify Telephone Number, take note of player response/phone manner in call. This call is made by Support Staff in the same language of the player account.
b. Check if player exists on local country phone book, tax records, electoral register, additional public databases, with the same information.
c. Request ID, Proof of Address, copies and statements of credit cards.
12. Reporting (Internal & External)
The Company’s policy is that any knowledge or suspicion of money laundering activities must be immediately reported to the MLRO.
On receipt of the report, the MLRO reviews the contents of internal reports, requests further information when required and then decides on the appropriate action to be taken. It also Company’s policy that each decision, in respect of each and every report received, needs to be recorded.
MLRO files a Suspicious Transaction Report (STR) if he suspects or has reasonable grounds to suspect that;
a. a transaction may be related to Money Laundering (ML) or Funding Terrorism (FT), or
b. a person may have been, is, or, may be connected with ML/FT;
c. or ML/FT has been, is being, or may be committed or attempted.
The STR is drawn up by the MLRO as soon as reasonably practicable, but not later than 5 working days from when the suspicion first arose.
The Company strictly prohibits any tipping off by its personnel to players. Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. Under no circumstances shall any officer, employee or appointed agent disclose or discuss any AML concern, investigation, notice or filing of the suspicious activity report with the person or persons subject of such, or any other person, including members of the officer's, employee's or appointed agent's family.
13. Record Keeping
It is Company policy to maintain the following records;
- a copy of, or the references to, the evidence of the client’s identity obtained;
- the supporting evidence and records in respect of the business relationships and occasional transactions which are the subject of customer due diligence;
- internal reports of MLRO and external reports made to the FIU;
- records of AML training provided to employees.
Records are maintained for a period of 5 years, beginning on the date on which the business relationship ends
14. Employee Vetting
The company follows high ethical standards in the recruitment of all its staff. This includes taking prospective employees professional background into account, performing background checks, obtaining a certificate of good conduct from the local police authority, and verifying references provided, as per HR processes.
15. Communication and Training
The Company commits itself to ensure that all personnel are provided with training on detection and treatment of transactions that may relate to money laundering. The level of training provided to an employee is appropriate according to the employee’s role and responsibilities within the Company.
Training of AML is directed to ensure that the Company’s employees are;
a. Able to identify a suspicious transaction;
b. Know the procedure to follow if such circumstances are encountered;
c. Know the provision of the relevant law and regulations with respect to ML/FT;
d. Be able to identify PEPs and perform proper KYC.
This AML manual is also available to all personnel of the Company.
16. Risk assessment and Compliance management
It is the policy of the Company to undertake a risk assessment for all clients and retain such assessment for a period of 5 years after we cease to act for the client.
