AML POLICY

BACKGROUND
1. The Company has extensive experience in protecting gaming businesses from criminal misuse and in establishing comprehensive anti-fraud and anti-money laundering policies, procedures, and in-depth staff training programs.
2. Future training programs will be based on thorough knowledge of the Proceeds of Crime Act and on money laundering indicators commonly identified within a gaming environment, especially in a Card Not Present transactional environment.
3. The director has full understanding of all provisions of the Proceeds of Crime Act and his responsibilities, and is well positioned to deliver expertise on Anti-Money Laundering measures and requirements, having safeguarded major remote and non-remote gaming businesses in this sector.
ANTI-MONEY LAUNDERING AND TRANSACTION FRAUD
1. Gaming environments are frequently targeted by individuals seeking to launder funds. The rapid pace of transactions and the availability of multiple payment processing methods make gaming businesses particularly exposed to this type of activity.
2. Accordingly, many of the initial operational and procedural decisions are either specifically designed to address this risk, or safeguards are strengthened as a natural outcome of the overall commercial and trading strategy adopted by the business.
3. ALL staff will receive training on Money Laundering indicators including, but not limited to:
  1. irregular betting behavior
  2. questionable deposit and withdrawal activity, including amount and frequency
  3. accuracy and consistency of card information
  4. issues related to customer verification and potential identity fraud
  5. linked accounts or the use of multiple accounts
4. All suspected Money Laundering cases must be reported to the MLRO. Such suspicion must not be disclosed to the customer, and no further action may be taken without the required consent. The MLRO is responsible for liaising with the relevant authorities and submitting Suspicious Activity Reports. He will also ensure that appropriate registers are maintained for all related reports.
5. The Company will implement a FULL ‘Know Your Customer’ policy. This will support efforts to address not only Money Laundering risks but fraud risks more broadly. Customers will be informed at registration, and generally on the supporting non-transactional website, that the Company uses online verification tools and that where verification criteria cannot be satisfied, identification and proof of address documents will be requested.
6. Additional protective measures will include setting withdrawal period thresholds and velocity limits. From the outset, checks and director approval will be required before processing card withdrawals and bank transfers exceeding 3000 EUR in a single transaction. A maximum of 3 daily withdrawals will apply, with an overall daily withdrawal limit of 9000 EUR.
7. In line with industry standards, Enhanced Due Diligence, requiring additional proof of identity and address, will always apply to withdrawals exceeding 3000 EUR within a single 24 hour period and 9000 EUR within a 90 day period. In such cases, simple online verification will NOT be sufficient.
8. The business will not include any cash transactions, thereby reducing risks linked to counterfeit currency.
9. Systems will operate to record all account transactions. Account histories will be subject to regular and ongoing reviews against fraud and social responsibility indicators. Where irregular betting or winning patterns are identified, these will be cross checked against call records to ensure that staff are not colluding with customers or engaging in improper conduct.
10. The Company will maintain a register of customers identified as high risk or politically exposed. Such accounts will be subject to enhanced monitoring and more frequent reviews.
11. Where unlawful or inappropriate conduct by staff is identified, investigation and disciplinary procedures will be carried out in accordance with staff contracts, employment law requirements, and the need to apply measures such as suspension, particularly where transactional fraud is suspected and such activities form a standard part of the employee’s role.
SECURITY AND MONITORING
1. It is vital to establish appropriate monitoring procedures within any gaming business, covering premises, equipment, personnel, communications, and transactions. The Company will introduce a range of measures and controls to maintain security and safety across these areas.
2. The Company has implemented call recording technology, which provides several advantages, including:
  1. supporting and enhancing staff training
  2. verifying the accuracy of bet details, including timing, placement, and transaction information
  3. safeguarding customer interests and protecting brand reputation
  4. introducing strong and regular monitoring controls designed to prevent and deter collusion between staff and customers
3. Users are required to provide all information reasonably requested by the Company to comply with jurisdictional obligations and to manage risks related to money laundering, terrorist financing, and economic or trade sanctions, as well as to ensure compliance with applicable laws and regulations in any jurisdiction.
4. You acknowledge that the Company may delay, block, or decline to process any Transaction and may immediately suspend or terminate your account without liability if there is suspicion that a Transaction:
  1. may violate AML or CFT laws or regulations in any jurisdiction;
  2. involves a sanctioned individual or entity, or is directly or indirectly connected to a sanctioned party under economic or trade sanctions imposed by any jurisdiction, or may directly or indirectly involve proceeds of unlawful activity or be intended for unlawful purposes.
5. Data protection and the security of software and hardware are critical for any business operating in a Non-Face to Face environment where transactions and data are recorded. Accordingly, the Company will adopt a comprehensive policy to encrypt all data wherever possible. Access to Shared Drives will be strictly restricted, monitored, and where necessary, protected by passwords. Data storage and backup solutions and procedures will be implemented to ensure that Customer Data remains inaccessible to unauthorized parties and is safeguarded against loss.
RESPONSIBLE RELATIONSHIPS WITH CUSTOMERS AND BUSINESSES
1. The Company will publish its Terms and Conditions together with KYC and AML policies on its website. These documents will specifically address fraudulent conduct, prior knowledge of an event outcome or likely outcome, as well as issues relating to match fixing and suspicious events. They will outline the actions that may be taken where cheating is suspected or confirmed and will explain the extent of cooperation with regulators and sports governing bodies in addressing such matters. This approach will generally support transparent communication with customers in these situations.
2. The director also recognizes that where serious criminal activity is suspected or detected, it is the responsibility of management and staff to ensure that individuals under suspicion are not tipped off regarding those concerns or any related investigations. In certain cases, alternative procedures may therefore be required. Appropriate staff training and clear escalation processes will be implemented.
3. The Company will take all appropriate steps to maintain integrity in its relationships with other businesses. This will involve a standardized due diligence process, often supported by Non Disclosure Agreements where necessary. The process will require disclosure of ownership and management structures, company incorporation information, registered address, and contact details. These reviews will follow a structured template and detailed records will be retained.