AML POLICY

The Company and its staff are dedicated to the highest standards of money laundering and terrorist financing prevention, including anti-fraud, anti-corruption, and anti-bribery. For this reason, we permanently employ sophisticated and effective risk assessment and due diligence measures. Our main goal is to ensure compliance with the applicable regulations, laws, and standards, and ensure a continuous practice of monitoring.

The money laundering regulations and legislation impose a severe responsibility upon the Company and its employees to combat money laundering in all its forms. We are committed to financial crime prevention and endeavor to improve existing measures.

The purpose of this policy is to ensure that the Company complies with the obligations and requirements set out by the Curacao legislation, regulations, and rules regarding the prevention, identification, and reporting of money laundering or terrorist financing.

We ensure adequate systems and controls are applicable to mitigate the risks posed to the Company and its clients, including the strict verification and due diligence of customers and their transactions. This policy provides guidance and a systematic approach for our employees to ensure that their knowledge and understanding of the financial crime regulations is exemplary, and sets out our expectations and their responsibilities under the regulations and our objectives.

We provide an effective training program under the money laundering regulations to ensure a thorough understanding and application of these regulations by our employees.

The Company will endeavor to protect its employees and clients from exposure to money laundering and terrorist financing and ensure a company-wide risk-based approach to the prevention of financial crime. Any actual or suspected acts of money laundering will be reported to the Curacao Financial Intelligence Unit (FIU) or other relevant governing authorities.

The Company reserves the right to initiate relevant examination procedures at any stage of relations with the user.

Regulations and Applicable Acts

1. Compliance with Curacao Ordinances and Decrees

This document is developed to be compliant with the following Curacao Ordinances and Decrees:

The National Ordinance on the Reporting of Unusual Transactions (N.G. 1996, no. 21), amended by N.G. 2009, no. 65 (NORUT) (N.G. 2010, no. 41);
The National Ordinance on the amendment of the Penal Code (penalization of terrorism, terrorist financing, and money laundering) (N.G. 2008, no. 46);
The National Ordinance on Identification of Clients when rendering Services (N.G. 1996, no. 23), amended by N.G. 2009, no. 66 (NOIS) (N.G. 2010, no. 40);
The National Decree containing general measures on the execution of articles 22a, paragraph 2, and 22b, paragraph 2, of the National Ordinance on the Reporting Of Unusual Transactions (National Decree penalties and administrative fines for reporters of unusual transactions (N.G. 2010, no. 70));
Ministerial Decree with the general operation of May 21, 2010, laying down the indicators, under article 10 of the National Ordinance on the Reporting of Unusual Transactions (Decree Indicators Unusual Transactions) (N.G. 2010, no. 27).

2. Supervisory Authority

2.1 Any organization subject to the Money Laundering Regulations must be monitored by a supervisory authority.

2.2 Curaçao participates in the Financial Action Task Force (FATF) as part of the Dutch Kingdom, and it has an established Financial Intelligence Unit (FIU) that we shall report any unusual transactions to, if any.

2.3 The Company’s Supervisory Gaming Authority is the gaming authority of Curacao.

3. Objectives

The Company aims to prevent financial crime and money laundering within the organization by meeting the following objectives:

3.1.1 Establish and maintain policies, controls, and procedures to mitigate and effectively manage the risks of money laundering and terrorist financing;
3.1.2 Report any suspected money laundering or terrorist financing to FIU Curacao;
3.1.3 Conduct due diligence and client identification procedures;
3.1.4 Conduct frequent and ongoing risk assessments and audits of all AML and CFT controls, systems, and procedures;
3.1.5 Appoint a Money Laundering Reporting Officer (MLRO) with sufficient knowledge and seniority to fulfill the tasks and objectives laid out in this document and any applicable internal documentation;
3.1.6 Abide by all applicable local and international legislation.

4. Real-time Monitoring of User’s Activity

4.1 The Company and its staff continue to oversee and monitor ongoing transactions from and to Customers to identify any malicious or fraudulent activity. We closely cooperate with our payment gateway providers as well as third-party services to flag suspicious transactions and Due Diligence will be applied where it is the case.

4.2 The monitoring system in place detects any attempt to register multiple accounts by controlling IP addresses. When a user requests a withdrawal, the system verifies for multiple accounts and checks if a false proxy server was used. If multiple accounts are found, they will all be closed, and the user will be prohibited from opening a new account.

4.3 If a user's deposits appear unusual and are flagged by the system, the department manager will reach out to the user for an explanation of the abnormal activity. If no satisfactory response or information is provided, the manager will suspend the account until the necessary documentation and explanation are provided. If the user fails to provide satisfactory information within 30 days, the account will be closed. Additionally, the manager will report the unusual or suspicious transaction to the relevant authority.

4.4 Winnings will be deposited only into the user’s bank account. Transfers or payouts to a third-party account will not be processed unless adequately justified and at the discretion of the Company.

5. Records Management

5.1 All documents, accounts and transactions associated with clients/customers are retained for a minimum of 5 calendar years from the occasional transaction or activity. Details of the below records are retained:

Identification and verification records;
Due Diligence checks;
Transaction lists.

6. Reporting

6.1 The MLRO is responsible for monitoring all anti-money laundering measures and raising SAR's when needed.

6.2 All documents relating to money laundering reporting, business transactions, client identification and customer due diligence are retained for a minimum of 5 years.

6.3 The appointed person shall ensure that the below minimums are met with regard to the information disclosed on any reports:

Full details of the people involved;
Full details of the nature of their/your involvement;
The types of money laundering activity involved;
The dates of such activities;
Whether the transactions have happened, are ongoing or are imminent;
Where they took place;
How they were undertaken;
The approx. and/or exact amount/s of money/assets involved;
What has given rise to the suspicion.

6.4 Using all the information available at the time, the MLRO makes an informed decision using sound judgment as to whether there are reasonable grounds for knowledge or suspicion of money laundering and to enable them to prepare their report for FIU (Financial Intelligence Unit), where appropriate.

7. Financial Sanctions List

7.1 The Company is using third-party providers to screen its customers for inclusion in any sanction/PEP lists in the world. The monitored watchlists are as follows:

Australia, DFAT Consolidated list;
Australian Sanctions (AU);
Bureau of Industry and Security - Entity List (US);
Bureau of Industry and Security - Unverified List (US);
Bureau of Industry and Security (US);
Canada, Office of the Superintendent of Financial Institutions, OSFI Consolidated;
CIA Leader list;
Consolidated Canadian Autonomous Sanctions List;
Department of State, AECA Debarred List (US);
Department of State, Non-proliferation Sanctions (US);
EU Financial Sanctions (EU);
European Union, Consolidated list of persons, groups and entities subject to EU financial sanctions;
Foreign Financial Institutions Subject to Part 561 (the Part 561 List);
Foreign Sanctions Evaders List (FSE);
INTERPOL Wanted List;
Non-SDN Iranian Sanctions Act List (NS-ISA);
OFAC Consolidated Sanctions List;
Office of the Superintendent of Financial Institutions (Canada);
Palestinian Legislative Council (PLC) List;
Sectoral Sanctions Identifications (SSI) List;
Specially Designated Nationals (OFAC);
Specially Designated Nationals List (SDN);
Switzerland Sanction List (SECO);
U.S. Department of Commerce, Bureau of Industry and Security - Denied Persons List;
U.S. Department of the Treasury, Foreign Office;
Assets Control (OFAC);
UK Financial Sanctions (UK);
The UK, Consolidated Financial Sanctions list (HMT);
United Nations Sanctions (UN);
United Nations Security Council (UN), Consolidated Sanctions list;
US Consolidated Sanctions (US);
US State Dept. WMD Non-Proliferation List.