Introduction
Money Laundering
Money laundering is the process of making 'dirty' money—funds obtained through criminal acts like drug trafficking or terrorism—appear legal. Criminals typically do this by inflating the funds or moving them through various channels to hide the money's origin and avoid detection.
Combating Money Laundering
This issue spans both legal and financial domains, requiring strict oversight from financial institutions to spot and stop the flow of illegal funds. To combat this, we follow a comprehensive program that focuses on:
- Facilitating the secure exchange of data between authorized regulatory bodies;
- Implementing strict protocols to verify the identity of our users;
- Keeping detailed logs and reporting any activity that seems suspicious.
Regulation
Our staff members managing remote gambling services are required to immediately flag and report any potential violations they encounter during their work. This obligation applies when there is:
- Suspicion;
- Concrete evidence or factual knowledge of a violation;
- Reasonable grounds to believe a person is involved in criminal activity, including the laundering of money.
Such suspicions must be reported to the proper authorities without delay. This is especially critical before establishing a business relationship with a new client, which is why we conduct regular legal screenings of all monetary transfers.
Special Rules
As a provider of online gambling, we are committed to following all regulatory standards and operating under our Curaçao gambling license, which is recognized globally.
Crime Prevention, Operational Irregularities, and AML Policy
Our approach to anti-money laundering is built upon several core operational principles:
- We perform routine audits of our internal controls and monitoring systems;
- All staff members involved in operations receive specialized training;
- We conduct a full risk assessment and RBI review at least once a year;
- We take complete ownership of our efforts to prevent money laundering within our ecosystem;
- Our actions are always governed by law, objectivity, and professional independence.
Risk Management
In accordance with UK law, we strictly follow the Money Laundering Regulations 2007 (the 'Act'). Our strategy involves a detailed analysis of potential vulnerabilities and the implementation of specific steps to neutralize those risks. To achieve this, we:
- Continuously monitor and refine our existing control mechanisms;
- Maintain a transparent log of all actions taken and the reasoning behind them;
- Apply specific procedures to manage the risks we have identified;
- Identifying any risks.
Suspicious Activity
Flag unusual transactions or behavior, such as when a user's deposit patterns deviate significantly from the norm. In these cases, we perform enhanced due diligence, verifying identities through passports, utility bills, or bank statements.
Suspicious Activity Reports
To maintain high security standards, we generate regular reports on suspicious behavior. Every employee is mandated to 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 may lead to criminal charges. To ensure maximum privacy, all OPA escalations must be submitted in writing rather than via email.
If a client is under investigation for illegal activity, employees are strictly forbidden from disclosing any information regarding the OPA until the case is closed.
Operating Procedure
Before any winnings are withdrawn, our team reviews the user's spending patterns and gaming history to ensure there are no red flags indicating suspicious activity.
For security reasons, we strongly advise users to withdraw their funds using the same payment method they used for deposits.
We review the entire transaction history of every customer to ensure that all deposits and transfers are legitimate.
Withdrawal Procedure
Before approving a payout, the platform must verify several key points to ensure the transaction is valid:
- Has the user been actively and consistently placing bets?
- Does the payment account used for the withdrawal belong to the account holder?
- Are the betting patterns and transaction volumes consistent with the user's expected profile?
Escalation Process
Strictly following ROB policies and reporting suspicious activity is vital for our company to maintain financial stability and prevent losses.
Senior Management
Senior management will be held accountable if it is discovered that illegal activities occurred and the required protocols were ignored.
Money Laundering Reporting Officer
We have appointed Nikos Lazos ([email protected], +35780077001) as our IODE specialist. He is directly responsible for detecting and preventing money laundering and ensuring our platform meets the obligations of the Proceeds of Crime Act 2000, as well as OPA requirements for our Malta-based systems. To be effective, 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 undergo mandatory training to fully understand their duty to report suspicious customer behavior or potential money laundering. Employees are reminded that ignoring these duties can lead to administrative penalties or criminal prosecution.
High Risk Jurisdictions
Users from jurisdictions flagged as high-risk for money laundering may undergo more frequent and rigorous identity checks. We base our high-risk list on data provided by the GFMDB:
- Afghanistan;
- Algeria;
- Angola;
- Bosnia and Herzegovina;
- Ecuador;
- Guyana;
- Iraq;
- Lao People’s Democratic Republic;
- Myanmar;
- Panama;
- Papua New Guinea;
- Syria;
- Uganda;
- Yemen;
- Iran;
- Democratic People’s Republic of Korea.
Accounting
We maintain comprehensive audit logs to assist law enforcement agencies in any financial investigations. Our accounting policies include:
- A clear reporting line from designated employees to senior management;
- Detailed records of all staff training and specific monetary transactions;
- Secure storage of identity and verification data for all active users;
- OPA logs for both internal and external communications;
- Records showing which staff members monitored compliance for specific OPAs.
Verification Process for New Users
When hiring new staff, we follow a strict vetting process to confirm the candidate is of legal age. We verify their identity and credentials using multiple independent sources.
Internal Security and Asset Protection
To prevent the misuse of our critical assets, we implement strict allocation and access controls. Our equipment is managed in coordination with Unicept Malta, ensuring secure visitor access, rigorous testing, professional destruction of confidential files, locked storage, and 24/7 security.
Compliance and Risk Committee
We are currently establishing a Compliance and Risk Committee, featuring the CODM, the Compliance Officer, and the Director. This group will meet at least every quarter, or more frequently if urgent issues arise.
Evaluating Partner Solvency and Reputation
We hold our suppliers to high ethical and professional standards. When choosing a partner, we evaluate them based on several key criteria:
- Their ability to consistently provide high-quality products;
- Full compliance with all relevant NAPs;
- Financial stability;
- A demonstrated commitment to corporate social responsibility.
Every potential supplier must go through a formal approval process where their provided information is thoroughly verified.
Compliance with the Proceeds of Crime Act
We strictly adhere to all procedures and policies mandated by the Proceeds of Crime Act 2002.
Internal Accounting
The following section outlines our 'Know Your Customer' (KYC) principles and how we stay current with legal and regulatory requirements.
- We retain all customer records for a minimum of six years, regardless of how active the user was or when the relationship ended;
- All documentation regarding money laundering probes and suspicious activity reports is archived for six years following the close of the investigation;
- Data related to all financial transfers and transactions is kept for a six-year period.
Collusion Prevention and Data Protection
By joining our platform, users agree to a contract stating that any form of fraud is strictly prohibited. If fraud is detected, accounts will be permanently blocked with no chance of recovery.
To protect payment data and secure user accounts, both our internal staff and the Payment IQ service have authorized access to payment information.
Know Your Customer
Introduction
By accepting our terms, you authorize us to perform any necessary background checks—including those requested by third parties—to verify your personal details. During this verification, we may temporarily freeze your ability to withdraw funds.
- 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 is of legal age, we reserve the right to restrict or suspend the gaming account.
Purpose of the Policy
There are several specific instances where our company may require users to verify their identity and service eligibility:
- If a user fails to comply with the rules and guidelines outlined in our official Terms and Conditions;
- Whenever there is a suspicion of fraudulent behavior, money laundering, or any financial transactions linked to criminal or terrorist activities;
- In cases where the identification documents submitted by the user appear invalid, forged, or otherwise unreliable;
- Any other circumstances that could potentially jeopardize the company's operational security or legal standing;
Should any of the above issues arise, we may request that you submit further information or provide copies of the following:
- Verification of your current permanent home address and place of residence;
- Full and correct full name;
- Full date of birth;
- Permanent Citizenship;
- Identification number;
- Specifically, the following types of documentation are acceptable for verification:
- Passport;
- Customer ID;
- National ID card;
- A clear photo of yourself holding your open passport so that both your face and the document are visible;
- A clear image showing the front side of your bank card;
Additionally, we may occasionally ask for documentation that verifies the origin of the funds you are using for gaming or betting activities.
Obligations:
- Due Diligence: To maintain regulatory standards, all clients must undergo a thorough vetting process, and the company will maintain detailed records of this verification.
- Anonymous Accounts: We strictly forbid the creation of accounts held in the name of a third party or any form of anonymous registration;
- Duplicate or Multiple Accounts: Opening several accounts to split gambling expenses or manipulate the system is not permitted;
- Politically Exposed Persons (PEPs): The company reserves the right to take appropriate action or restrict access if political figures or their immediate family members attempt to use the platform.
Furthermore, we reserve the right to deny a customer's application or end our professional relationship immediately and without providing a specific reason if our 'Know Your Customer' (KYC) policy is breached.