Anti-Money Laundering Policy

Date: 21 April 2022

1. Preliminary provisions

1.1. This Anti-Money Laundering Policy (hereinafter referred to as the "Policy") describes in detail the measures, actions, and procedures that the Service Provider must follow in accordance with the legislation of the country of incorporation and the regulatory requirements of the Service Provider country and the countries in which the Service Provider operates (hereinafter referred to as the "Rules"), to detect and prevent attempts to money laundering and terrorist financing. The Service Provider implements the Policy by creating an effective system to prevent money laundering and terrorist financing. The basis for the adoption of this Policy is the "Money Laundering: Best Practice Guidelines for the Online Gaming Industry Rules and Guidelines" (hereinafter referred to as the "Guidelines")

1.2. Subjects obligated to implement the Policy, and especially the Service Provider's Administration, are responsible for updating the Policy in accordance with the Rules and Recommendations and other provisions that govern the system for preventing money laundering and terrorist financing. All employees and divisions of the Service Provider are required to implement this Policy.

1.3. "Client" in accordance with this Policy means the following: a person, a player, a client who has entered all the mandatory information in the registration form and created a gaming account on the Service Provider's Website (hereinafter the "Website") in order to use the services

1.4. Money laundering involves the performance of acts that obscure the origin of money or other assets presumably acquired illegally, including:

1.4.1. Exchange or money transfer of or any other such property

1.4.2. Hiding the true source, location, disposition, movement, ownership, or other rights concerning money or other property

1.4.3. Acquisition, possession, or use of money or other property

1.5. Terrorist financing means providing or collecting funds, or attempting to provide or collect funds, legal or illegal, to use them or know that they will be used to commit terroristic acts by terrorists or terrorist organizations

1.6. The Service Provider works with the relevant competent authorities (hereinafter referred to as the "Authorities") to help to prevent money laundering and terrorist financing. In this Policy, competent authorities mean the relevant public authority of the country of incorporation of the Service Provider or the authority of the country where the Service Provider operates and which is responsible for compliance with the legal and supervisory functions established in the Rules

2. Regulatory framework

2.1. National regulation

2.1.1. Following the National Anti-Money Laundering Ordinance (1993), money laundering is a criminal offense in Curaçao. The following describes other major national regulations regarding money laundering and terrorist financing, among others:

a)   Criminal Code (Penal Code) (N.G. 2011, no. 48)
b)   National Ordinance for the Reporting of Unusual Transactions (N.G. 1996, No. 21), as last amended by N.G. 2009, No. 65 (N.G. 2010, No. 41) (NORUT) will approve all amendments to it and all relevant national decrees containing general measures and decrees of the respective ministries concerning general operations
c)   National Ordinance on the identification of customers in the provision of services (NG 1996, No. 23) as last amended by H. 2009, No. 66 (NG 2010, No. 40) (NOIS) together with all amendments thereto and all relevant national decrees, containing general measures, and decrees of the respective ministries concerning general operations
d)   National Ordinance containing general measures to implement Articles 9, paragraph 2, and 9a, paragraph 2 of the National Ordinance on the identification of customers in the provision of services. (National Ordinance on General Penalties and Administrative Fines for Service Providers) (N.G. 2010, No. 70)
e)   National Sanctions Decree on "Al-Qaeda", "Taliban" in Afghanistan, Osama bin Laden, and terrorists to be listed locally (N.G. 2010, No. 93)
f)    National Decree on the obligation to report cross-border movements of money N.G. 2002, no. 74) together with all their amendments and all relevant national decrees containing general measures and ministerial decrees concerning general operations

2.1.2. These laws and regulations serve as the basis for procedures maintained by the Curaçao financial sector to identify and prevent industry-related risks of money laundering, terrorist financing or other criminal activity

2.2. International regulation

2.2.1.  As a member of the Financial Action Task Force (www.fatf-gafi.org) and the Caribbean Financial Action Task Force (www.cfatf-gafic.org), Curaçao adheres to international standards by regularly implementing these standards into its national legislation

2.2.2. Internationally, the FATF plays a very important role in the fight against money laundering, terrorist financing and the proliferation of weapons of mass destruction

2.2.3. The FATF monitors the progress of its members in implementing the necessary measures, analyzes methods and countermeasures to combat money laundering and terrorist financing, and contributes to the adoption and implementation of appropriate measures around the world

2.2.4. In carrying out these activities, the FATF cooperates with other international organizations involved in the fight against money laundering and terrorist financing. Nowadays, 34 countries are direct members of the FATF, and more than 180 countries are connected to the FATF through regional organizations

3. Measures and actions to prevent money laundering and terrorist financing

3.1. The measures, actions, and procedures applied to prevent money laundering and terrorist financing established by the Policy include:

3.1.1. Assessment of the risk of money laundering and terrorist financing

3.1.2.  Implementation of measures for client due diligence

3.1.3.  Appointment of a Money Laundering Reporting Officer (hereinafter "MLRO")

3.1.4. Regular professional training and education of the Service Provider's employees

3.1.5. Regular internal audits

3.1.6. Preparation and regular updating of the indicators list to identify suspicious Clients’ actions and transactions

3.1.7. Notification and assistance to the Authorities on money laundering issues

3.1.8. Data storage and protection

3.1.9. Creation of an appropriate information system. Performing other tasks, obligations in accordance with the Regulations and this Policy

4. Client Verification Procedure (CDD)

4.1.  The Service Provider checks the Clients:
•    when establishing business relations with the Client (registration process)
•    at the first payment request from the Client
•    if there are doubts about the reliability of the previously received Client data
•    always, regardless the size of the transaction, when there are suspicions of money laundering or terrorist financing in relation to the payment made or the Client
When registering, the geographic location of the potential Client's PC IP address is checked to ensure that the person is in an authorized jurisdiction. If the potential client is not in an authorized jurisdiction, he/she will not be allowed to proceed with the registration process

4.2. Client verifications

Client identification

4.2.1.  Collection of mandatory data about the Client

4.2.1.1. The client must fill in all the required information in the registration form, namely to confirm the identity, address, and contact information, including a valid email address, place of residence, relevant payment information. All information must be correct and valid. No person under the age of 18 (eighteen) years old can be registered as a Client. Any deposited funds or winnings received by such people will be transferred to the Authorities

4.2.1.2. Email confirmation. When the Client has signed in on the Website, an email is sent to the Client to confirm the email address. The Client must click on the link inside the email to confirm that this is his real email address

4.3. Additional verification

4.3.1. The Service Provider has a right to conduct additional checks when the Client is requesting for payment and sometimes before requesting if the Service Provider suspects that the Client is making any fraudulent payments or performing fraudulent actions that affect the outcome of the game, or an automated system has identified suspicious payments

4.3.2. We ask Clients to send or upload the following documents:
•    Bank account statement from which the funds were deposited
•    photo of both sides of the bank card from which the funds were deposited. All digits of the card number, except the first six and the last four, must be covered in the picture. If the embossing is visible on the back side of the card, it must be closed as well as the CVV2 code
•    identity document (driver's license / passport / identification code)

4.3.3.  The Service Provider reserves the right to take additional measures to verify the Client identity when transferring funds to a gaming account on the Website. To verify the Client, the Service Provider has the right to request identity proof (including, but not limited to: a copy of the passport/identity card, proof of payment cards ownership, a utility bill in the name of the Client, or a Skype video call). If the Client does not provide or cannot provide such information, the Service Provider may suspend the gambling account until the Client provides this information and/or permanently close the gambling account in case of inability to provide the requested information and/or documents.

4.4. Politically exposed person (PEP)

4.4.1. The ability to determine if a Client is a PEP is entirely dependent on the effective implementation of CDD measures, including the requirements for identification, verification, and compliance with the requirements set out in this Policy, as well as the effective application of a risk-based approach

4.4.2. Appropriate risk management systems are used to determine if a potential Client is a PEP. This means taking proactive steps, such as evaluating Clients based on criteria and risk profiles, reviewing CDD information, and the Service Provider's own research to determine if a Client is a PEP

4.5. Payouts

4.5.1. Payouts or refunds are made to the same account from which the Client made the initial transfer

4.6. Cash payments

4.6.1. The Service Provider cannot accept cash payments from Clients and cannot pay out winnings in cash. Funds can be received only in one of the ways mentioned on the Website, in the "Cashier" section

4.7. Funds Withdrawal

4.7.1. The Client can withdraw less or equal to the amount of balance on his gaming account. It is possible by sending a request to the Service Provider to withdraw funds from the Client's gaming account. Withdrawal notification must be sent via the Website. The Service Provider does not accept requests for withdrawals by phone or email. The Service Provider's employees are prohibited from violating this rule

5. Monitoring client activity

5.1. For the Service Provider to know its Client and the source of origin of the funds received, the Service Provider must constantly monitor transactions and closely monitor the activity of its Clients, applying the following measures:
•    monitoring and checking the compliance of the Client's actions with the expected purpose of opening a gambling account
•    monitoring and verifying the compliance of the Client's transactions with their usual scope of activities by comparing new and previously collected data
•    general monitoring and updating of collected documents and Client data

5.2. In case the Service Provider suspects one of the following:

5.2.1. The Client carries out fraudulent activities, collusion, coordination with other players or any other illegal activity related personally to the Client or third parties, and/or uses prohibited types of various programs, methods and/or equipment; or
5.2.2. The Client’s deposits and withdraws funds from the system, using the system as an intermediate object for transferring money

5.2.3. The Service Provider investigates each situation on a case-by-case basis. If the particular case is considered suspicious, The Service Provider will report this to the designated MLRO for further investigation

5.3. Money Laundering Reporting Officer(MLRO)

5.3.1. Employees through the Service Provider's internal information channels are obliged to inform MLRO about any suspicious actions of the Client. The application must contain the following information about the Client: full name, address, date of birth, basis of suspicion, and details of the transaction. Employees should report any suspicions as soon as possible

5.3.2. Once a problem is reported to MLRO, employees are expected to follow further directions from MLRO and cease independent investigations into the matter. The MLRO will decide if the disclosure is required to the Authorities and, if necessary, will refer the matter to the appropriate Competent Authority. Employees should not notify a Client suspected of money laundering about an investigation, even if they have received confirmation from MLRO, as this may be considered an offence, namely "disclosure of private information"

6. Prevention of money laundering and terrorist financing

6.1. When processing data about the Client's gaming account and performing transactions, the Service Provider interacts with rating agencies, that detect fraud and prevent money laundering

6.2. After the registration of the Client, the Service Provider uses software to prevent fraud and duplication of gaming accounts, which compares the data of the Clients, for example, name, address, telephone number, and IP address. If a duplicate is found, the Service Provider will restrict access to such a gaming account of the Client. The client will not able to withdraw funds without providing KYC (Know Your Client) documents

6.3. The Service Provider complies with all relevant anti-money laundering and terrorist financing regulations. The Service Provider is obliged to report all suspicious transactions to the competent authority

6.4. When money laundering or terrorist financing is suspected, the Service Provider takes all necessary measures and may close the Client's gaming account and block access to all funds, if required by the Rules

6.5. By going through the registration process on the Website, the Client confirms and indicates that the Client does not violate the laws of any country or state. In addition, by accepting the provisions of this Policy and/or the Terms of the Website, the Client who is the owner of the payment card must confirm that he/she is entitled to use the goods and/or services offered on the Website. If the Client uses the services of the Website, such as games, the Client must provide legally significant confirmation that he/she meets the age of majority specified by the legislation of the Client's jurisdiction, required to use the services of the Website

6.6. When using the services of the Website, the Client assumes full responsibility for compliance with the laws of any country or state where this service is used and confirms that the Service Provider is not responsible for any illegal or unauthorized violations. By opening a gambling account on the Website, the Client agrees to abide by and fulfil the obligations set out in this Policy. The Service Provider is not liable for any damage that may arise as a result of the Service Provider's actions, in fulfilling any obligations set in the Policy, or any actions taken as required by the relevant competent Authority

6.7. The Service Provider's policies ensure that its technologies are prevented from being used for money laundering and terrorist financing. Procedures include additional identity checks and ongoing monitoring of completed transactions

6.8. The Service Provider works only with Clients who are natural persons. Legal entities are prohibited from having a gaming account on the Service Provider's Website and from withdrawing funds to these accounts

6.9. The Service Provider uses the list of restricted territories and jurisdictions specified in the Terms to avoid accepting payments and making payments to Clients in territories with an uncertain status

6.10. When the Service Provider checks documents, each document should be checked separately to ensure that they are not tampered with (modified with a graphical editor). To check bank cards, the Service Provider's employees must check the data through the BIN database (binbase.net) to make sure that the bank card in the photo provided is issued by the bank. The Service Provider also matches the country of the card from the BIN database with the address shown on the utility bill

6.11. The Service Provider reserves the right to use additional procedures and tools to verify compliance with all Service Provider's anti-money laundering and anti-terrorist financing policies

6.12. The Service Provider is working on creating an appropriate information system that will effectively implement all measures and actions specified in the Rules and Policies to identify unusual or suspicious transactions based on risk indicators and other factors

6.13. It is of crucial importance that the Service Provider's employees are completely honest, whose integrity is not in doubt. To achieve this, the Service Provider follows a procedure whereby all applicants must provide curricula vitae, at least two certificates, and relevant educational and/or professional certificates, which are verified by the Service Provider’s HR department