AML Policy
THIS AML POLICY IS DRAFTED IN ENGLISH. ANY TRANSLATION INTO ANOTHER LANGUAGE IS ONLY FOR THE CONVENIENCE OF THE READER. IN THE EVENT OF ANY CONFLICT OR INCONSISTENCY, THE ENGLISH LANGUAGE VERSION SHALL PREVAIL OVER ANY TRANSLATED VERSION.AML Policy/Procedures
Standards set out in this AML and KYC policy/procedures documents are based on applicable legal and regulatory requirements, especially on the EU AML directive (Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (Text with EEA relevance) in order to effectively prevent any money laundering, terrorist financing or other fraudulent activities.
The Company uses its best endeavors to adhere to high standards of anti-money laundering/counter terrorist financing (AML/CTF) regulations and requires management and employees to adhere to these standards in order to prevent the use of Company’s products and services for money laundering/terrorist financing purposes. Implemented AML/CTF compliance program comprise policies and procedures including but not limited to:
• Client identification and verification;
• Ultimate Beneficial Owner identification and verification;
• Identification of AML/CTF risks;
• Effective implementation of AML/CTF policies and procedures to ensure compliance with AML laws and regulations;
• Enhanced due diligence of high-risk clients;
• Identification of clients, who qualify as Politically Exposed Persons (PEPs);
• Internal procedures for monitoring and reporting suspicious activities of the client’s;
• Client screening against global list of terrorists and specially designated nationalities, relevant financial and other sanctions lists;
• Staff training and awareness raising through specialized trainings and courses;
• Maintenance of relevant records;
• Management of regulatory inquiries and incidents;
• Coordinating day-to-day compliance by responsible compliance staff.
KYC Policy/Procedures
The Company adheres to high standards of required Know Your Client procedures (KYC). These KYC policy/procedures encompass the following measures:
• Client’s identification;
• Client’s acceptance/non-acceptance policy/guidelines (client’s under age, clients from restricted/sanctioned territories not accepted);
• Monitoring of high-risk clients;
• Obtaining of any information, which could be of importance with regard to AML risk;
• KYC procedures take place when the respective transaction is to be carried out;
• KYC procedures are carried out permanently considering the identified risks.
The Company’s management, employees, agents are trained to deal with AML related matters and respond to transactions that raise suspicion of money laundering or financing of terrorism.
Records of all documents obtained for the purpose of identification and all transaction data, as well as other documents are kept electronically for at least 10 years.
Risk-Based Approach
The Company adopts a Risk-Based Approach (RBA) when assessing the risks related to AML/CTF. The Company’s guidelines are the following:
• Prior to conducting any transaction, the Company conducts checks to ensure that the identity of the client does not match with any person with known criminal background, banned entities, or terrorists;
• The relevant data shall be obtained from the client prior to conducting the respective transaction;
• The process of risk assessment of the clients may encompass the assessment of client’s background, country of origin, source of funds and volume of transactions;
• The company may carry out enhanced due diligence with regard to client’s, which can be considered as high-risk based on the findings of the Company;
• The company may carry out enhanced due diligence with regard to funds the origin of which are unclear or for the transactions of higher value and frequency.
Client Identification
The Client Identification Program is to be carried out:
• before any financial transaction can be made;
• when there is any doubt about the authenticity, veracity, or adequacy of the previously obtained Clients’ identification data.
• requires Clients to provide proof of identification and if necessary, proof of residence; and
• does not under any circumstances permit any transaction to be made with
• incomplete identity and if needed residence verification information.
Politically Exposed Persons
The Company has a special policy with regards to Politically Exposed Persons (PEPs); The Company carries out PEP checks at any time at its sole discretion; In case the mentioned checks show that the Player is a PEP, the Company reserves the right to terminate the Account and transfer back the existing deposits to the Player. In such case the Company may at its sole discretion charge the Player with the administrative fee in amount of 20% of the amount transferred.
Required Information
Clients go through verification process where they submit:
• Name;
• Email address;
• Date of birth;
• Identity verification;
• Residence verification.
Compliance Officer
The Compliance Officer is an employee of the company and is responsible for the effective enforcement of the AML/KYC Policy. Compliance Officer duties are the following:
• Collecting Clients’ identification information;
• Monitoring of the respective transactions;
• Elaborating and establishing internal policies and procedures for the completion, review, submission and retention of all reports and records as required from competent authorities;
• Maintenance of AML records;
• Providing law enforcement with information as required under the applicable laws and regulations;
• The Compliance Officer is responsible and entitled to communicate with competent law enforcement authorities, which are involved in prevention of money laundering, terrorist financing, and other illegal activity;
• Training of the staff.
