Anti-Money Laundering Policy

1. Policy Overview & Commitment

This Anti-Money Laundering (AML) Policy establishes our commitment to preventing money laundering, terrorist financing, and other financial crimes. This document outlines our comprehensive framework for identifying, assessing, and mitigating AML risks in accordance with applicable laws and regulations.

We recognize the critical importance of maintaining robust AML controls to protect the integrity of the financial system, safeguard our organization, and comply with legal obligations. We have established a comprehensive compliance framework that aligns with both domestic and international standards to detect and deter illicit activities on our platform. Our approach is based on a Risk-Based Assessment (RBA) utilized throughout the customer lifecycle.

2. Regulatory Compliance Framework

We adhere strictly to the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations. Our operations prohibit any illicit activities, including money laundering, terrorist financing, or violations of trade sanctions, in line with various global AML regulations.

Our compliance team actively monitors updates from the Financial Action Task Force (FATF) to maintain high compliance standards. Our key practices include:

Developing and maintaining policies, procedures, and controls to combat money laundering, terrorist financing, and sanctions violations.

Establishing an internal AML/KYC team to oversee these protocols.

Providing ongoing training to our staff.

Conducting regular independent reviews to ensure compliance and address any identified deficiencies.

3. Glossary of Terms & Definitions

Money Laundering: Transforming illegal gains into seemingly legitimate funds, typically through placement, layering, and integration stages.

Placement: Introducing illegal proceeds into financial systems via deposits or other means.

Layering: Disguising the origins of criminal proceeds through complex financial transactions.

Integration: Reintroducing laundered money into the economy as legitimate to evade detection.

Suspicious Activity: Transactions that suggest fraud or illegal activities by users or non-users.

Sanctions: Measures imposed by international bodies to restrict activities of targeted entities or nations.

Our Chief Compliance Officer oversees the implementation of our AML policies, driving initiatives, and ensuring adherence to evolving regulatory requirements.

4. Client Due Diligence (CDD)

We apply rigorous due diligence and continuous monitoring using advanced software to comply with legal standards. Our due diligence process involves verifying the identity of all customers before or during the establishment of a business relationship, monitoring ongoing transactions to ensure they are consistent with our knowledge of the customer and their risk profile, and keeping all collected data and records up to date.

5. Know Your Customer (KYC)

Our KYC process, based on a Risk-Based Approach (RBA), helps us understand and assess the profiles of our players. This includes collecting essential information at registration and during account management. Our Customer Identification Program (CIP) includes:

Collecting key data such as personal details and email at account creation.

Monitoring the risk associated with accounts and funding methods.

Keeping records of identification data.

Screening against lists of known or suspected terrorists or their organizations.

6. Identity and Age Verification

To ensure the validity of user information and compliance with KYC requirements, we employ third-party verification services. These services verify users' identity and age to confirm they are eligible to use our platform, confirm users are not from restricted or sanctioned jurisdictions, and check global sanctions lists to ensure users do not appear on them.

7. Customer Information

We collect detailed user information to establish a well-informed belief regarding the identity of our users, aligned with their risk profile. This information may include name, address, country, date of birth, and postal code, collectively known as "KYC Information". We ensure all necessary KYC Information is collected prior to allowing full access to our services. We do not permit corporate entities or non-natural persons to register.

8. Geo-blocking for Prohibited and Sanctioned Jurisdictions

We implement IP address-based geo-blocking to ensure services are not offered in countries where such activities are illegal. We also ensure that users are not subject to sanctions from the following jurisdictions: Austria, France and its territories, Germany, Netherlands and its territories, Spain, Union of Comoros, United Kingdom, USA and its territories, all FATF Blacklisted countries, and any other jurisdictions deemed prohibited by the Anjouan Offshore Financial Authority.

9. Enhanced Due Diligence (EDD)

For users who display indicators of suspicious behavior or those involved in high-risk transactions, we conduct enhanced due diligence. This may include verifying the user's full legal name, country of citizenship, permanent address, identification number (such as taxpayer identification, passport number, or other government-issued ID number), and documentation of their source of funds and wealth.

10. Restrictions

We will block users who:

Fail to provide requested identification information.

Submit fraudulent identification documents.

Attempt to misrepresent their location.

Are from restricted or prohibited jurisdictions.

Are subject to global sanctions or watch lists.

Are identified as being addicted to gambling or having mental health issues.

Have funds originating from restricted jurisdictions.

We reserve the right to suspend or block players for any other reasons deemed necessary.

11. Transaction Monitoring

We are committed to adhering to economic and trade sanctions and have established a transaction monitoring program. This includes both manual and automated processes to identify and address any unusual activities in real-time and through ongoing monitoring. Our systems review user history and activity patterns to detect and report unusual behavior and implement necessary controls.

12. Ongoing Monitoring of Transactions

In addition to the above, we implement procedures for ban evasion detection, time zone monitoring, and product and service reviews to prevent misuse of our platform and ensure compliance with our terms of service. We periodically evaluate our third-party service providers to ensure they meet our compliance requirements.

13. Vendor Management

We collaborate with reputable third-party service providers as part of our compliance infrastructure. We regularly assess the performance of these providers to ensure they meet our operational and compliance standards. If a service provider is not meeting expectations, or if additional services are required, we may take remedial action or seek alternative solutions to maintain our compliance with regulatory requirements.

14. Internal Training

We ensure that our employees receive regular training on Anti-Money Laundering (AML), anti-terrorist financing, and compliance with trade sanctions. These training sessions are conducted periodically and are tailored to the specific needs of our staff, based on the latest regulatory developments and best practices in the industry.

15. Suspicious Transaction Reporting (STR)

We are committed to adhering to applicable regulations concerning the reporting of unusual or suspicious transactions. If a customer is identified as being linked to money laundering, terrorism financing, or other criminal activities, such activity will be reported as suspicious to the relevant regulatory authorities. This is part of our broader effort to maintain a safe and legal gaming environment and to fulfill our regulatory obligations.

16. Complaint Submission & Resolution Process

Players may submit complaints on issues including but not limited to: deposits or withdrawals, bonus terms and conditions, account closures or restrictions, game errors or fairness concerns, responsible gaming enforcement, KYC/verification, data protection, technical/software issues, and AML concerns.

16.1 Only registered players may submit complaints. Players may lodge a complaint up to 6 months after settlement of the bet or incident. Complaints may be submitted via email, live chat, or the online submission form.

16.2 Responsible Gaming Complaints: Acknowledgement within 2 business days, resolution within 5 business days (up to 2 weeks if delays are unavoidable).

16.3 Other Complaints: Acknowledgement within 7 days, resolution within 4 weeks (extendable once by an additional 4 weeks with notice).

17. Alternative Dispute Resolution (ADR)

Players may escalate unresolved complaints to a certified ADR provider, free of charge. ADR details are available in our Terms & Conditions and on our website. ADR outcomes are binding once concluded and cannot be reopened with another provider. Players retain the right to pursue legal action, unless otherwise limited by ADR terms.

18. Record-Keeping & Reporting

Complaints are logged and reported to the relevant regulatory authority twice annually. Reports include total complaints, resolved cases, pending cases, ADR referrals, and legal actions. Records of unresolved or escalated complaints will be kept for up to 5 years or as required by law. The regulatory authority may request complaint records at any time.