Anti-Money Laundering Policy

Last updated: 1st September 2024

1. Introduction

Money Laundering

Money Laundering (ML) is the process of creating the appearance that funds obtained from criminal activity, such as drug trafficking or terrorist activity, originate from a legitimate source. Criminals attempt to launder money by disguising the source and/or changing the form of funds, or moving them to locations where they are less likely to attract attention.

Anti-Money Laundering

Anti-Money Laundering (AML) refers to the legal and regulatory controls designed to prevent, detect, and report money laundering activities.

An effective AML framework requires a jurisdiction to:

• Criminalise money laundering;
• Provide regulators and law enforcement with investigation powers;
• Require financial institutions to identify customers, apply risk-based controls, maintain records, and report suspicious activity;
• Enable information sharing with other jurisdictions where appropriate.

2. Regulation

Employees working within the remote gaming industry are required to report information obtained in the course of business where they know, suspect, or have reasonable grounds to suspect money laundering or terrorist financing.

The Merchant must demonstrate that adequate risk assessments and customer due diligence measures are conducted prior to establishing business relationships and throughout the ongoing monitoring process.

3. Crime & Disorder and AML Policy

Our AML policy is based on the following principles:

• Establishing systems and controls that comply with legal and regulatory requirements;
• Conducting annual AML risk assessments and adopting a risk-based approach;
• Ensuring senior management oversight and responsibility;
• Maintaining transaction records for law enforcement purposes;
• Providing ongoing AML training to employees;
• Supporting the nominated AML officer with sufficient authority and resources.

4. Risk Management

We adopt a risk-based approach to identify, assess, manage, and mitigate money laundering and terrorist financing risks. This includes:

• Identifying relevant risks;
• Implementing appropriate policies and procedures;
• Monitoring and improving controls;
• Documenting actions and decisions.

5. Suspicious Activity

Suspicious activity may include unusual transactions, abnormal player profiles, or deposits inconsistent with a customer’s known profile.

Enhanced Due Diligence (EDD) may require documents such as:

• Passport or ID card;
• Utility bill;
• Bank statement;
• Other proof of identity.

Suspicious Activity Reports (SARs)

Employees must report suspicious activity to the Risk Team. Disclosure to the customer or any third party (“tipping off”) is strictly prohibited and may result in criminal penalties.

Working Procedure

Before processing withdrawals, the Merchant reviews deposit history, turnover, and ensures funds are returned to the original payment method where possible.

Withdrawal Procedure

Withdrawals are subject to AML verification and risk review prior to approval.