AML/CFT Policy

• Customer identification and due diligence requirements
• Requirements for reporting unusual and suspicious transactions
• International AML/CFT standards and guidance
• AML reporting system requirements

• Applicable anti-money laundering and counter-terrorist financing legislation
• A risk-based approach to AML/CFT
• FATF Recommendations and standards
• Sanctions regimes (UN, EU, and others)

• Business Risk Assessment (BRA): Annual assessment covering customers, products, delivery channels, geography, and technology (including crypto).
• Customer Risk Assessment (CRA): Players are classified as Low, Medium, or High risk. Higher-risk customers receive Enhanced Due Diligence (EDD).

• Standard CDD: At registration or before NAf 4,000 cumulative deposits/transactions:
  1. Full name, date of birth, residential address, email, phone
  2. Government-issued photo ID verification
• Enhanced Due Diligence (EDD) for:
  1. High-risk jurisdictions
  2. Politically Exposed Persons (PEPs)
  3. Large or unusual transactions
  4. Crypto deposits
  5. Source of funds / source of wealth verification required
• Ongoing monitoring of player activity.

• Screening at onboarding and ongoing (real-time where possible).
• UN, EU, and other sanctions lists.
• PEP status triggers mandatory EDD and senior management approval.

• Automated systems monitor for red flags such as:
  1. Rapid deposit/withdrawal cycles
  2. Structuring to avoid thresholds
  3. Inconsistent betting patterns
  4. Crypto mixer or high-risk wallet involvement
• Unusual transactions are investigated and reported.

• All suspicious activities or transactions meeting indicators (objective or subjective) are reported to the competent Financial Intelligence Unit (FIU) via goAML.
• Threshold-based reporting (e.g., NAf 5,000+) and suspicion-based reporting.
• Tipping-off is strictly prohibited.

• Crypto accepted only for gambling activity.
• Strict segregation of player, operational, and treasury wallets.
• Blockchain analytics tools for wallet screening and transaction monitoring.
• Enhanced due diligence for crypto transactions.
• Compliance with applicable virtual asset guidelines.

• Oversees the AML/CTF program
• Has direct access to senior management
• Ensures staff training and internal reporting
• Files UTRs with goAML

• Mandatory initial and annual training for all staff.
• Specialized training for customer-facing and compliance roles.
• Records of training are maintained.

• CDD, transaction, and monitoring records retained for a minimum of 5 years (or longer as required by law).
• Records are secure, searchable, and available to competent authorities upon request.

• Independent audits of the AML/CTF program.
• Annual policy review or upon regulatory changes.
• Non-compliance may result in disciplinary action and regulatory reporting.