Prevention of Money Laundering

Prevention of Money Laundering

Anti-Money Laundering Policy

Introduction

Money Laundering

Money laundering (ML) is the process of making illegally obtained funds, such as those from drug trafficking or terrorist activities, appear to come from a legitimate source. Criminals attempt to launder money by hiding its origin, changing its form, or moving it to locations where it is less likely to attract attention.

Anti-Money Laundering

Anti-Money Laundering (AML) refers to the legal controls that financial institutions and other regulated entities must implement to prevent, detect, and report money laundering activities.

For an effective AML program, a jurisdiction must:

  • Criminalize money laundering.

  • Grant authorities and regulators the necessary powers and tools for investigations.

  • Require financial institutions to verify customer identities, establish risk-based controls, maintain records, and report suspicious activities.

  • Share information with other jurisdictions when necessary.

Regulation

Employees working in the remote gaming industry must report information they receive during their duties when:

  • They are aware of money laundering or terrorist financing activities.

  • They suspect such activities.

  • They have reasonable grounds to believe that a person is involved in money laundering or financing terrorism, including handling criminal proceeds.

These obligations collectively fall under the term "knowledge or suspicion." Authorities expect that a risk assessment is conducted before entering a business relationship with a customer, and that adequate customer due diligence is performed to ensure transactions align with the customer’s risk level.

Merchants must demonstrate that ongoing monitoring is conducted based on a risk-sensitive approach and that all records reflecting this process are maintained. This document outlines additional measures applied for risk monitoring and the situations in which we will request customers to declare the sources of their funds in high-risk cases potentially involving money laundering.

Special Regulations

The merchant is committed to ensuring compliance is integrated into all aspects of its operations and that the Curaçao Gaming License allows for legal gaming operations in the international market.

Crime, Corruption, and AML Policy

Our AML policy is based on principles and practices:

  • We develop systems and controls appropriate for our business and in compliance with legal and regulatory requirements.

  • We assess AML risks in our business at least annually, adopting a flexible, effective, proportionate, and cost-efficient risk-based approach.

  • Full commitment and accountability come from senior management.

  • We regularly evaluate the adequacy of our systems and controls.

  • When necessary, we maintain transaction records to assist in law enforcement investigations related to money laundering and terrorist financing.

  • We provide initial and ongoing training to all relevant employees.

  • We allocate resources and authority to designated officers to work objectively and independently.

Risk Management

As required by the Money Laundering Regulations (2007), we have a policy and procedure for risk assessment and management. This risk-based approach includes several steps to assess and mitigate money laundering and terrorist financing risks:

  • Identifying money laundering and terrorist financing risks relevant to our business.

  • Designing and implementing policies and procedures to manage and reduce these assessed risks.

  • Monitoring and improving the effectiveness of these controls.

  • Keeping records of actions taken and reasons for those actions.

This approach ensures efforts are focused where they are most needed and effective, with full commitment from senior management and active participation from all employees. We have assessed our business risks regarding money laundering, considering both the threats and their impact.

Suspicious Activity

Suspicious activity may include unusual transactions, excessive player profiles, or inconsistencies in deposits. Our risk monitoring approach applies specific enhanced due diligence controls to player profiles when necessary. Examples include:

  • Passport or ID card.

  • Utility bill.

  • Bank statement.

  • Other identity verification documents.

Enhanced due diligence controls depend on the player's profile and associated risk. If multiple factors are identified, the customer is flagged, and risk monitoring is conducted. This includes verifying their employment, home value, place of residence, and whether their spending aligns with their declared financial situation.

Suspicious Activity Reports (SARs)

Suspicious Activity Reports (SARs) are mandatory. The merchant ensures that employees report any suspicion of a person or customer being involved in money laundering or terrorist financing to the Risk Team. Failure to do so may result in criminal prosecution.

SAR escalations should be handled discreetly, in written form, and not via email to ensure maximum confidentiality.

Employees must never disclose AML concerns to the subject of an investigation ("tipping off"), as this is strictly prohibited and carries severe legal consequences.

To protect ourselves, we do not leave any indications on accounts suspected of money laundering and reserve the right to request full account details at any time.

Operational Procedure

The merchant reviews players' spending and gaming activities to detect suspicious activities. Before any withdrawal, the following procedures are performed:

  • The customer's deposit history is reviewed to confirm no suspicious payments were made to their account.

  • The frequency and amount of deposits are analyzed to ensure they align with the customer's transaction history and general deposit range in our network.

  • The customer’s turnover is reviewed to ensure they are genuinely playing in the casino and not using the merchant as a money transfer method.

Whenever possible, funds should always be returned to the original payment method used for deposits.

Withdrawal Procedure

Before a withdrawal is processed, the AML department must answer the following questions:

  • Has the player placed bets?

  • Is the payment method registered under the player’s name, and was it used for deposits?

  • Do the player's transactions and betting behavior align with expectations?

Escalation Process

Following AML policies and escalating any suspicious activity is crucial to protecting the company from financial losses and ensuring compliance with various jurisdictions.

Any suspicious activity, no matter how minor, must be escalated. Failure to report money laundering suspicions can lead to criminal prosecution.

Employees

Senior Management

Senior management is fully committed and responsible for implementing this policy. They are aware that any complicity or negligence in money laundering can lead to personal liability.

MLRO (Money Laundering Reporting Officer)

The designated Money Laundering Reporting Officer (MLRO) is responsible for detecting money laundering and terrorist financing activities and fulfilling obligations under the Proceeds of Crime Act 2000 (POCA) and equivalent legislation in Malta.

The MLRO's responsibilities include:

  • Reporting AML and Counter-Terrorist Financing (CTF) activities to senior management.

  • Receiving information from employees under POCA Section 7 and the Terrorism Act 2000 Section 3.

  • Filing external reports when necessary.

The MLRO operates independently and has the necessary resources to fulfill their duties.

Training

All personnel will receive training on money laundering reporting obligations and the procedures in place to report any suspicious activity to the MLRO. Employees will be made aware that failing to comply with legal requirements, such as allowing a customer to spend criminal proceeds, can result in criminal or regulatory action.

Employees will receive training on:

  • Customer Due Diligence (CDD) requirements, including enhanced due diligence for high-risk customers (PEPs).

  • Reporting suspicious activities and obtaining proper approval before processing transactions.

High-Risk Jurisdictions

High-risk countries are those identified in Financial Action Task Force (FATF) publications or determined by the Gambling Commission. Enhanced Due Diligence (EDD) is always applied to customers from high-risk countries.

Players from FATF-listed jurisdictions that pose significant money laundering or terrorist financing risks will be rejected.

Record Keeping

To aid financial investigations, we maintain audit trails covering:

  • Compliance monitoring details.

  • Delegation of AML/CTF duties.

  • Reports to senior management.

  • Customer identification and verification data.

  • Transaction records.

  • Staff training records.

  • Internal and external SARs.

  • Communications with law enforcement or the National Crime Agency (NCA).

Prevention of Fraud and Internal Misconduct

Merchant promotes ethical business practices at all levels. We ensure that all new suppliers undergo a rigorous approval process to verify their financial stability, legal compliance, and commitment to corporate responsibility.

All customer transactions and records are maintained for a minimum of six years to comply with AML laws.

Merchant strictly prohibits fraud and will close customer accounts found to be engaged in fraudulent activities.