The Policy on Prevention of Money Laundering and Terrorist Financing (AML)

Effective from 25 July, 2020

PREAMBLE

  1. The Policy on Prevention of Money Laundering and Terrorist Financing (hereinafter — «the Policy») outlines the minimum general unified standards of anti-money laundering and combating terrorism financing which must be adhered to by the whole of and the constituent parts of the Company.
  2. In any country or jurisdiction where the applicable anti-money laundering and terrorist financing laws and regulations require to establish higher standards, such country standards must be adhered to.
  3. Compliance with this Policy is mandatory and essential for ensuring that all companies regardless of geographic location, business profile and operating role fully comply with applicable anti-money laundering and terrorism financing laws and regulations of respective countries and jurisdictions.
  4. Our Company is committed to periodic review and critical reassessment of this Policy in light of the business strategies, goals and objectives on an ongoing basis.

2. DEFINITION OF MONEY LAUNDERING AND TERRORIST FINANCING

2.1. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Money laundering may generally occur in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from illegal or criminal activities is converted into monetary instruments, such as money orders or traveller's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

2.2. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, possibly for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organisations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money, such funding could be of cumulative nature over extended periods, and the associated transactions may not be complex.

2. OBJECTIVE OF THE POLICY

3.1. The Company is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimize and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

3.2. The Company will endeavour to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organization and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.

3.3. The Company’s policies, procedures and internal controls are designed to ensure compliance with all applicable laws, rules, directives and regulations relevant to the Company’s operations and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place.


4. COMPANY POLICY

4.1. It is the policy of Seven Digital Solutions N.V (the “Company") to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. The Company strives to comply with all applicable requirements under the legislation in force in the jurisdictions in which the Company operates, to prevent of the use of the financial system for the purpose of money laundering and terrorist financing.

4.2. The Company is licensed and regulated by Antille Phone N.V. to offer remote games over the internet, under the National Decree August 18, 1998 No. 14. Under the license conditions issued by Curaçao, the Company is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity.


5. AML RISKS

5.1. As any online money-taking and cash-processing business, the Company is exposed to a variety of risks related to potentially improper use of the Company’s business facilities in the interests of those involved in money laundering and terrorist financing. While these risks are inherent and cannot be entirely avoided, the Company believes that the risks could be identified and contained via effective use of the AML procedures, systems and personnel.

  • The Company identified the following key Money Laundering and Terrorist Financing risks (ML&TF risks).
  • The risk of accepting the customers whose identities and/or addresses are hidden to conceal the direct relation to ML&TF (for example, use of multiple passports to conceal the true identity or residential address.)
  • The risk of taking, as a deposit for online gaming via the Company’s website, the funds that have, unbeknownst to the Company, been originated from illegal and/or terrorist-supporting sources (for example, transfer of gambling funds directly from FATF-censured jurisdictions.)
  • The risk of providing an unintended financial conduit or repository for the funds originated in the course of illegal and /or terrorist-supporting activities (for example, temporary “parking” of funds without the direct use in e-gambling activities.)
  • The risk of illegal funds transfer (withdrawal) by the customers via the Company’s website facility (for example, placing the funds without the intention of using them in gambling or betting activities).
  • The risk of unknowing conduct, certain functions of the financial institution for any of the customers beyond the usual business remit (for example, by saving, exchanging or transferring the customer funds at the customer requests).

5.2. The Group recognises that in addition to the aforementioned risks there may exist various other unknown sources of ML&TF threats to the business. While identification and prevention of such threats are beyond the Company’s normal business capacity, the management believe that fostering the general alertness, risk awareness and the spirit of constructive scepticism among employees is the best general preventive measure that could prevent ML&TF risks from materialising.

5.3. In view of the management, ML&TF risks and business risks are intertwined inextricably hence assessment of ML&TF risks at the Company is a part of the systematic risk assessment regularly conducted by the Company’s management.


6. ML&TF RISK ASSESSMENT

6.1. Risk assessment process for ML&TF threats is arranged along two different dimensions – nature and complexity of the risk; and value of the risk.

6.2. Along the first dimension, there exist a number of risk triggers that allow for identification of the nature and complexity of the risk, i.e. country of the player, currency selected by the player, changes in the registration information, e-wallets selection, types of games selected and others. A particular combination of triggers signals that the ML&TF risk is simple or complex in nature. Relative simplicity or complexity further determines the Company response and mitigation measures towards the risk.

6.3. Along the second dimension, an analytical attempt is made to assess the geographical scope and monetary value of a specific ML&TF risk. For example, the first deposited amount from a new customer is usually accepted at the lowest allowable threshold for a given jurisdiction thus containing the ML&TF risk of improper use of the Company’s customer account facilities for depositing the funds. Further continuation of relationships and ordinary deposit-gaming-withdrawal patterns by the customer usually lead to increases in the values of allowable deposits and withdrawals. Gradually, the Company relationship with a customer builds up thus allowing for an equally commensurate increase in the volumes of the business conducted.

6.4. Based on the dimensions described above, a specific ML&TF risk is classified as being high or normal; depending on classification, different actions are called for from the AML&TF officer and employees involved in ML&TF controls. Typical actions for high-risk detection situations are increasing in the time lag for withdrawals and acceptance of the customer funds and deep verification of the customer.


7. INTERNAL CONTROLS

7.1. The Company’s internal controls are a set of policies and procedures aimed at securing the efficient and compliant business of the Company and provision of the safe and fair gambling environment for the customers.

7.2. Internal controls in relation to ML&TF risks consist primarily of systematic application of the rules and procedures laid out in the corresponding sections, requirements of this Policy and the Regulations. In its entirety, the internal control system at the Company is designed to ensure that the ML&TF risks are forewarned and contained with a reasonable degree of confidence and efficiency.


8. AML&TF DESIGNATED OFFICER

8.1. The Company designated AML&TF Compliance Officer, with full responsibility for the AML&TF programme. This compliance officer is also designated as MLRO.

8.2. The compliance officer has a working knowledge of the Company’s business environment, risks inherent to the Company’s business model and AML&TF provisions. AML&TF Compliance Officer also performs the duties of Money Laundering Reporting Officer at the Company and is responsible for reporting suspicious AML&TF transactions to Local Authority.

8.3. General duties of the AML&TF Compliance Officer include monitoring of the Company’s compliance with the AML&TF obligations, assessment of the business risks both internal and external, oversight of the AML&TF related communication and training for employees, and reporting of the findings and critical issues of the AML&TF systems and procedures to the managers and executives of the Company. The AML&TF Compliance Officer ensures that the Company keeps and maintain all required AML&TF records and that suspicious activity reports are filed with the local authority when required and appropriate. The AML&TF Compliance Officer is vested with full responsibility and authority to enforce the Company’s AML&TF Policy and working programme.

8.4. Responsibilities of AML&TF Compliance Officer:

  • Spearheads the Company’s global AML&TF and is responsible for the Company’s overall AML&TF strategy and policies.
  • Conducts escalation and sanctioning in cases of internal non-compliance or lack of quality with AML&TF strategy and policies.
  • Represents AML&TF activities at the Company’s Board level.
  • Manages central AML&TF function of the Company and controls adequacy of policies, organisational structure and resources devoted to AML&TF compliance.
  • Drives communication to the Board and other stakeholders with respect to issues concerning AML&TF compliance.
  • Maintains relationships between AML&TF function and the Company’s external auditors, regulators and other compliance authorities.
  • Oversees and presents to the Board overview and budget of the AML&TF activities on a yearly basis.
  • Contributes to the elements of the IT-systems related to AML&TF compliance.
  • Presents to CEO and the Board the yearly AML&TF Compliance Report.
  • Reports to CEO and the Board all cases of non-compliance or inadequate compliance with AML&TF policies and procedures, together with recommendations for improvement.

9. PLAYER IDENTIFICATION PROGRAM

9.1. The Company will take reasonable steps to establish the identity of any person for whom it is proposed to provide its service (hereinafter “Players"). For this purpose, the process for the registration of Players provided for under the General Terms and Conditions of the Company provides for the due diligence process that must be carried out before the opening of a user account.

9.2. The Company will keep at all times a secure online list of all registered Players and information and documents will be retained in accordance with the applicable data protection obligations.

The Company will collect certain minimum Player identification information from each Player who opens an account. The Company will not accept to open anonymous accounts or accounts in fictitious names such that the true beneficial owner is not known. The information required will include at least:

  • Player’s date of birth (showing that the player is over eighteen (18)
  • years of age);
  • Player’s first and last name;
  • Player’s place of residence;
  • Player’s valid email address; and
  • Player’s username and a password.

Documents to verify the identity information received will be requested from the Player if and when there is considered to be risk or uncertainty about the information provided and prior to any payment in excess of 1,50,000 INR occasion or when payments to the account are made in excess 1,50,000 INR. These documents shall include, to the extent permitted under the relevant data protection regulations:

  • A copy of a valid identity card or passport;
  • Proof of address;
  • The Company may supplement the use of documentary evidence by using other means, which may include:
  • Independently verifying the Player’s identity through the comparison of information provided by the Player with information obtained from a reporting agency, public database or other source;
  • Checking references with financial institutions; or
  • Obtaining a financial statement.

9.6. The Company will inform relevant Players that the Company may seek identification information to verify their identity.

9.8. Any employee of the Company who becomes aware of uncertainty in relation to the accuracy and truthfulness of the Player information provided shall immediately notify the AML Compliance Officer, who will review the materials and determine whether further identification is required and or so that it may be determined whether a report is to be sent to the relevant authorities.

9.9. If a potential or existing Player either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the Company will not open a new account and, after considering the risks involved, consider closing any existing account. In either case, the AML Compliance Officer will be notified so that it may be determined whether a report is to be sent to the relevant authorities.

9.10. If a Player has been identified as attempting or participating in any criminal or unlawful activity, the Company will take the appropriate steps to immediately freeze the account of the Player.

9.11. If any material personal information of a Player changes, verification documents will be requested.


10. CONTINUOUS TRANSACTION DUE DILIGENCE

10.1. The Company will monitor account activity with special attention, and to the extent possible, the background and purpose of any more complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.

10.2. Monitoring will be conducted through the following methods: Transactions will be automatically monitored and reviewed daily for all transactions above 1 000 EURO or its equivalent in INR along with all the details of the users making those transactions. Documents may be required at the determination of the AML Compliance Person.

10.3. The AML Compliance Officer will be responsible for this monitoring, will review any activity that the monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the relevant authorities.

10.4. Parameters that signal possible money laundering or terrorist financing include have mentioned in this Policies.

10.5. The Company will not accept cash or non-electronic payments from Players. Funds may be received from Players only by any of the methods described in Terms and Conditions.

10.6. The Company will only transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.

10.7. To the extent the Company utilizes a third party to process and record payments to and from Player and accounts, the Company will use best efforts to ensure the services provider has transaction monitoring systems in place which will allow for screening of the transactions pursuant to these provisions and in accordance with the applicable legislation. The AML Compliance Officer shall be responsible to review the relevant service agreement with the service provider to ensure the adequacy of the agreement.

10.8. Records relating to the financial transactions shall be maintained in accordance with the data protection and retention requirements in the applicable jurisdiction of Curaçao.


11. SUSPICIOUS TRANSACTIONS AND REPORTING

11.1. Additionally to the provisions stated herein, the AML Compliance Officer will report any suspicious transactions (including deposits and transfers) conducted or attempted by, at or through a Player account involving EUR 1,000 or its equivalent in INR or more of funds (either individually or in the aggregate) where the AML Compliance Officer knows, suspects or has reason to suspect:

The Player is included on any list of individuals assumed associated with terrorism or on a sanctions list;

The transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade laws or regulations or to avoid any transaction reporting requirement under law or regulation;

The transaction has no ordinary lawful purpose or is not the sort in which the Player would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or

The transaction involves the use of the Company to facilitate criminal activity.


12. TRAINING PROGRAMS

12.1. The Company will develop ongoing employee training under the leadership of the AML Compliance Officer and senior management. The training will occur on at least an annual basis. It will be based on the Company’s size, its Player base, and its resources and be updated as necessary to reflect any new developments in the law.

12.2. The training will include, at a minimum:

how to identify red flags and signs of money laundering that arise during the course of the employees’ duties

what to do once the risk is identified (including how, when and to whom to escalate unusual Player activity or other red flags for analysis;

what employees’ roles are in the Company’s compliance efforts and how to perform them;

the Company’s record retention policy;

the disciplinary consequences for non-compliance with legislation.


CONTACTS

If you have any questions on the BetJungle AML Policy, please contact us at support@betjungle.com

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