Introduction
Money Laundering
Money laundering is the process of making 'dirty' money—funds obtained through criminal acts like drug trafficking, terrorism, or other illegal ventures—appear legitimate. Criminals typically do this by inflating the funds or moving them through various channels to hide the original source and avoid detection.
Combating Money Laundering
This issue spans both legal and financial domains. To combat it, financial institutions employ strict oversight to spot and stop the flow of illegal funds. Our strategy for fighting money laundering focuses on several key pillars:
- Facilitating the secure exchange of intelligence with the relevant regulatory authorities;
- Implementing robust protocols to verify the identity of our users;
- Maintaining detailed logs and reporting any transactions that seem out of the ordinary.
Regulation
Staff members managing our remote gambling services are required to immediately report any red flags or potential violations they encounter during their work. This obligation applies when there is:
- Suspicion;
- Concrete evidence or factual knowledge of illicit activity;
- Reasonable grounds to believe a person is involved in financial crimes, including money laundering.
These scenarios are treated as serious suspicions and must be reported to the authorities promptly. This is especially critical during the initial onboarding phase; therefore, we regularly screen all monetary transactions for legal compliance.
Special Rules
As an online gambling provider, we are committed to following all regulatory standards and operating under our Curaçao gaming license, which is recognized globally.
Crime Prevention, Irregularities, and AML Policy
Our approach to preventing money laundering is built upon these core principles and practices:
- We conduct frequent audits of our internal controls and system performance;
- We provide comprehensive training for all operational staff;
- We perform a full risk assessment and review our RBI (Risk-Based Approach) at least once a year;
- We accept full accountability for the effectiveness of our anti-money laundering efforts;
- We maintain a standard of legal integrity, objectivity, and independence in all our actions.
Risk Management
In accordance with UK law, we strictly follow the Money Laundering Regulations 2007 (referred to as the \"Act\"). Our strategy involves analyzing potential vulnerabilities and taking proactive steps to neutralize them. Our specific actions include:
- Constantly reviewing and refining our existing control mechanisms;
- Keeping a transparent audit trail of all actions taken and the reasons behind them;
- Executing specific procedures to manage the risks we have identified;
- Identifying any risks.
Suspicious Activity
Flagging suspicious behavior, such as deposits that don't align with a user's typical profile. To prevent abuse, we perform strict due diligence, verifying identities via passports, utility bills, and bank statements.
Suspicious Activity Reports
Security is our priority, which is why we generate regular reports on suspicious activity. Every employee must notify the risk assessment team if they suspect a user is linked to financial terrorism or money laundering. Failure to report known evidence is a serious offense and can lead to criminal charges. To maintain maximum secrecy, these internal escalations must be submitted in writing rather than via email.
If a customer is under investigation for illegal activities, employees are strictly prohibited from disclosing any details regarding the case until the investigation is closed.
Operating Procedure
Before any winnings are withdrawn, our team reviews the user's betting patterns and spending habits to ensure no suspicious activity occurred during the gaming process.
For security and verification purposes, we strongly advise users to withdraw funds using the same payment method they used for deposits.
We audit the entire transaction history of every client to ensure that all deposits and payments are legitimate.
Withdrawal Procedure
To authorize a payout, the platform must verify several key points to ensure the transaction is safe:
- Has the user been consistently and actively placing bets?
- Does the payment account used for the withdrawal belong to the registered account holder?
- Is the user's betting and transaction behavior consistent with their expected profile?
Escalation Process
Strictly adhering to ROB (Risk-Based) policies and reporting suspicious activity is vital for the company's financial stability and the prevention of losses.
Senior Management
Senior management will be held personally accountable if it is discovered that illegal activity was overlooked or that necessary actions were not taken.
Money Laundering Reporting Officer
We have appointed Nikos Lazos (IODE) as our dedicated specialist. He can be reached at [email protected] or +35780077001. His primary role is to detect and prevent money laundering and ensure the platform meets its obligations under the Proceeds of Crime Act 2000, specifically for our Malta-based systems. To do this effectively, the IODE operates independently and has full access to all necessary corporate resources.[email protected], +35780077001, who is directly responsible for preventing the detection of any illegal activity related to money laundering. This specialist is also responsible for the fulfillment of the gaming platform’s obligations under the Proceeds of Crime Act 2000 and separately for the OPA related to the systems located in Malta. In order to perform its duties properly, the IODE has the right to act independently and to have constant access to all resources that may contribute to the fulfillment of professional duties.
Staff Training
All operational staff must complete mandatory training to understand their duties regarding the reporting of suspicious activities. Employees are clearly informed that ignoring these responsibilities can result in administrative or criminal penalties.
High Risk Jurisdictions
Users from jurisdictions flagged as high-risk for money laundering may undergo more frequent and rigorous checks. We refer to the GFMDB list for these regions, which currently includes:
- Afghanistan;
- Algeria;
- Angola;
- Bosnia and Herzegovina;
- Ecuador;
- Guyana;
- Iraq;
- Lao People’s Democratic Republic;
- Myanmar;
- Panama;
- Papua New Guinea;
- Syria;
- Uganda;
- Yemen;
- Iran;
- The Democratic People’s Republic of Korea.
Accounting
We maintain a comprehensive audit log to assist law enforcement agencies in their investigations when necessary. Our accounting policies cover the following:
- A clear reporting line from designated employees to senior management;
- Detailed records of staff training and logs of incidental financial transactions;
- Secure storage of all identity verification documents for active clients;
- Internal and external logs regarding OPA (Official Police/Authority) communications;
- Detailed reports on which staff members monitored compliance for specific OPA cases.
New Client Verification Procedures
When hiring new staff, we implement a thorough vetting process to verify their legal age, identity, and credentials using multiple independent sources.
Protecting Assets from Internal Theft and Misuse
To protect our critical assets, we implement strict allocation and access controls. Our infrastructure is shared with Unicept Malta, allowing us to utilize advanced security measures such as visitor access logs, rigorous testing, secure document destruction, lockable storage, and professional security services.
Compliance and Risk Committee
We are in the process of establishing a Compliance and Risk Committee, which will include the Director, the Compliance Officer, and the CODM. This group will meet at least every quarter, or more often if urgent issues arise.
Evaluating the Solvency and Reputation of Business Partners
We maintain high ethical standards when choosing our suppliers. When evaluating potential partners, we look for the following:
- A proven commitment to delivering high-quality products;
- Full compliance with all relevant National Action Plans (NAPs);
- Financial stability;
- A strong commitment to corporate social responsibility.
Every potential supplier must go through a formal approval process where all provided information is carefully vetted.
Our Obligations Under the Proceeds of Crime Act
We fully implement all procedures and policies required by the Proceeds of Crime Act 2002.
Internal Accounting
Below is a summary of our 'Know Your Customer' (KYC) principles and how we stay compliant with current laws.
- Regardless of a user's activity level, we archive all account records for a minimum of 6 years after the business relationship has ended;
- All documentation regarding money laundering probes and suspicious activity reports is kept for 6 years following the conclusion of the case;
- All records of financial transfers and transactions are stored for a 6-year period.
Collusion Prevention and Data Protection Compliance
By using our platform, users agree to a contract stating that any form of fraud is strictly forbidden. If fraud is detected, the account will be permanently blocked without the possibility of recovery.
To ensure the highest level of payment security, our internal team and the Payment IQ service have authorized access to transaction data.
Know Your Customer
Introduction
By accepting our terms, you grant us permission to conduct any necessary background checks, including those requested by third parties, to verify your personal details. Please note that withdrawals may be temporarily paused while this verification is underway.
- We reserve the right to immediately close any account if we find that the user has provided false or misleading information;
- If we cannot verify that a user has reached the legal gambling age, we reserve the right to restrict or close the account.
Purpose of the Policy
There are several specific scenarios where our company may ask you to verify your identity or confirm the services you are using:
- If we discover that you have breached any of the rules outlined in our official Terms and Conditions;
- When there are reasonable grounds to suspect involvement in fraudulent schemes, money laundering, or the financing of criminal or terrorist activities;
- In cases where the identification documents you submitted appear invalid, inconsistent, or otherwise suspicious;
- Whenever any other circumstance arises that could potentially jeopardize the company's legal or operational standing;
Should any of the above situations occur, we may request that you provide further clarification or submit copies of the following:
- Proof of your current permanent residential address and location;
- Full and correct full name;
- Full date of birth;
- Permanent Citizenship;
- Identification number;
- Specifically, we may require the following types of documentation:
- Passport;
- Customer ID;
- National ID card;
- A clear 'selfie' or photograph of yourself holding your open passport;
- A photo showing the front side of your payment card;
Additionally, we reserve the right to request documentation that verifies the origin of the funds you are using for your gaming or betting activities.
Obligations:
- Customer Due Diligence: To ensure compliance, all users must undergo a standard vetting process, and the company will maintain detailed records of this verification.
- Anonymous Accounts: We strictly forbid the creation of accounts under a pseudonym or any form of anonymous registration;
- Duplicate or Multiple Accounts: Creating several accounts to split gambling expenses or manipulate the system is not permitted;
- Politically Exposed Persons (PEPs): The company maintains the right to take specific action regarding account requests from political figures or their immediate family members.
Finally, we reserve the right to decline a registration request or end our professional relationship with a user immediately and without prior notice if they fail to comply with our 'Know Your Customer' (KYC) requirements.