AML Policy

All capitalized terms used herein and not defined herein have the respective meanings provided therefor in the terms and conditions

Experience

The company’s top management has lengthy experience in securing gaming businesses against criminal misuse and implementing wide-ranging anti-fraud and anti-money laundering processes, procedures and extensive staff training programs.

Underpinning future training programs will be knowledge of the proceeds of Crime Act and Money laundering indicators usually detected in a gaming environment particularly in a Card Not Present transactional environment

The director is fully aware of all aspects of the proceeds of Crime Act and his responsibilities and is well placed to impact knowledge and Anti-Money Laundering measures and requirements having secured major remote and non-remote gaming businesses in this field.

Anti-Money laundering and transaction fraud

Gaming environments are often targeted by those wishing to launder money. The speed of transactions and use of multiple payment processing options make gaming businesses especially vulnerable to this activity.

As a result, many of the initial trading and procedural decisions of the director are either directly aimed at combating this threat or protections are enhanced as a byproduct of the overall commercial and trading approach/strategy taken by the business.

All staff will be given training in Money Laundering indicators such as (but not limited to):

  Unusual betting patterns

  Suspicious deposit and withdrawal patterns (size and frequency)

  Reliability of data provided

  Customer verification issues and identify theft

  Account linkage/multiple accounting

All instances of suspected Money Laundering attempts must be reported to the MLRO but that suspicion must not be conveyed to the customer and further actions must await consent. The MLRO is then responsible for liaising with, submitting suspicious activity reports, and seeking consent through the go AML system of the financial intelligence unit (FIU) where and when appropriate. He will also ensure that appropriate registers are kept for all related reporting.

 The company will implement a full “Know your customer” policy. This will assist in tracking not just Money Laundering Threats generally. Customers will be advised at registration and generally on the supporting non-transactional website that the company will utilize online verification tools and that in instances where we are not able to satisfy criteria, ID and address verification documents will be requested.

Other key procedures that will strengthen these protections include implementing time thresholds and velocity limits for withdrawals. Additionally, card withdrawals and bank transfers exceeding the equivalent of 7,500 EUR in any supported currency within a one-week period will require additional checks and director approval. There will be a limit of three daily withdrawals, with a total daily and monthly cap of 15,000 EUR.

Industry accepted standards that will always lead to enhanced Due Diligence (the requirement for further proof through ID and address) will be withdrawals in excess of 3000 EUR in a single 24-hour period and 45000 EUR in a 90- day period. Simple online verification will not be acceptable in these circumstances.

The businesses will also not have any cash elements to it, mitigating risks associated with counterfeit money.

Systems will be operating to record transactions for an account. These account histories will be subject to a program of regular and continual checks against fraud and social responsibility indicators. Where unusual bet patterns and winning patterns are detected, these will be cross-referenced to call history to ensure that staff are not colluding with customers or acting illicitly.

Company will also keep a register of those customers that it identifies as high-risk or politically exposed. Those accounts will be subject to greater scrutiny and frequency of checks

In general, where illegal or inappropriate behavior by staff is identified, investigatory and disciplinary procedures will follow those outlined in staff contracts as required by employment law directives and the need to use in greater propensity, measures such as suspension when for example transactional fraud is suspected and those activities form a standard part of an employee’s job description.

Security and monitoring

It is essential to implement adequate monitoring procedures in any gaming business across premises, equipment, people, communications and transactions. The company will implement a range of measures and procedures to ensure security and safety in these areas.

The company has installed Call recording technology. This has multiple benefits that include:

 Staff training

 Ensuring the accuracy of bet (timing and placement) and transaction data;

 Customer and brand reputation protection

 Implementation of robust and frequent monitoring procedures that will guard against and deter collusion between staff and customers.

The protection of data and the security of software and hardware generally are of a prime concern for any business where transactions and data are recorded in a Non-face environment. Consequently. Company will implement an overarching policy of ‘Encrypt whatever can be encrypted’. Access to shared drives will be strictly limited and monitored and where appropriate, password protected. Data storage and back-up solutions/procedures exist to ensure that customer data is not accessible to outside parties and reliably prevent loss of data.

Responsible relationships with customers and businesses

 The company will be publishing terms and conditions along with KYC and AML policies on its website. These will make specific references to fraudulent activity, prior knowledge of a result or the likely result of an event, and matters relating to match-fixing and suspicious events. It will detail the actions we may take where cheating is suspected or identified and will detail the extent to which we will cooperate with regulators and sports governing bodies to tackle these matters. This will in general allow a transparent communication process with customers in these instances.

However, the director acknowledged that in the event that serious criminal activity is suspected or identified. It is also incumbent on them and staff that those suspected of this activity are not ‘tipped off’ as to those suspicions and subsequent investigations and that in some instances, alternative approaches will be required. Appropriate staff training and escalation procedures will be in place.

Company will take all necessary measures to ensure the propriety of its relationships with other businesses. This will entail a standardized due diligence approach often accompanied by Non-disclosure agreements where appropriate. This will require default disclosure of ownership and management structures, company incorporation details, address and contact details. Details of these investigations will be templated and records kept.