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 a case the Company may at its sole discretion charge the Player with the administrative fee in the amount of 20% of the amount transferred. 

Required Information (If needed)

Clients go through an automated verification process where they submit:

Name;

Email address;

Date of birth;

Copy of ID/Passport

Proof of residence (bank statement, Utility bill, similar – not older than 3 months).

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;

Updating risk assessment;

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.

AML & KYC Checks

The Gaming Control Anjouan is responsible for ensuring that all licensed gambling operators on the island of Anjouan comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations. To achieve this, the company Management has implemented a structured framework that involves several key steps, including:

Risk Assessment: The company Management conducts a thorough risk assessment of each licensed operators and service providers to identify any potential money laundering or terrorist financing risks. This involves analyzing the operator’s business operations, customer base, and geographical location.

AML and KYC Policies and Procedures: Based on the results of the risk assessment, the company Management develops and implements AML and KYC policies and procedures that are tailored to each operator’s specific risk profile. These policies and procedures outline the processes and controls that the operator must follow to identify and mitigate AML risks.

Customer Due Diligence (CDD): The company Management requires operators to perform CDD on all customers before they can engage in any gambling activities. This involves verifying the customer’s identity and assessing their level of risk based on factors such as their source of funds and occupation.

Ongoing Monitoring: The company Management requires operators to conduct ongoing monitoring of their customers’ transactions and behavior to detect any suspicious activity that may indicate money laundering or terrorist financing.

Reporting: If an operator detects any suspicious activity, they are required to report it to the Gaming Control Anjouan’s Financial Intelligence Unit (FIU) as soon as possible. The FIU then analyzes the report and may refer it to law enforcement authorities if necessary.

Training and Education: The company Management provides training and education to operators on AML and KYC regulations, including best practices for detecting and preventing money laundering and terrorist financing. This helps to ensure that operators are equipped with the knowledge and skills they need to comply with the regulations.

By implementing this structured framework, the Gaming Control Anjouan is able to effectively manage AML and KYC risks in the gambling industry on the island of Anjouan, and ensure that licensed operators are operating in compliance with local and international AML and KYC regulations.