1. INTRODUCTION
We seek to offer the highest security to all of our users and customers on the Website. Because we operate on a cryptocurrency-only basis, a risk-based verification process is implemented to confirm the identity of our customers where required, to establish that the details of the registered individual are correct, and to establish that the funds and wallets used are not stolen, sanctioned, or controlled by a third party. Our goal is to establish a general framework in the fight against money laundering. We also consider that, depending on nationality, origin, and the nature of the assets used, different safety measures must be taken for deposits and withdrawals.
The Website's team also puts reasonable measures in place to control and limit money laundering (ML) and terrorist financing (TF) risk, including the use of blockchain analytics, wallet screening, and the dedication of appropriate resources.
2. DEFINITION OF MONEY LAUNDERING
Money laundering is understood as:
The conversion or transfer of property, especially money or digital assets, knowing that such property is derived from criminal activity or from participation in such activity, with the purpose of concealing or disguising the illegal origin of the property or helping any person involved in the commission of such an activity evade the legal consequences of that person's or entity's actions.
The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from participation in such an activity.
The acquisition, possession, or use of property, knowing at the time of receipt that such property was derived from criminal activity or from assisting in such an activity.
Participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the actions referred to in the points above.
Money laundering shall be regarded as such even when the activities that generated the property to be laundered were carried out in the territory of another State or in that of a third country.
3. AML ORGANIZATION
The AML Compliance Officer (AMLCO) is responsible for the enforcement of the AML policy and procedures within the system. The AMLCO operates under the direct responsibility of general management.
4. AML POLICY CHANGES AND IMPLEMENTATION REQUIREMENTS
Each major change to the Website's AML policy is subject to approval by general management and the AMLCO.
5. VERIFICATION
Verification must be completed by any user or customer when required by our risk-based approach in order to withdraw funds or continue using the service. Depending on the deposit and withdrawal patterns, the amounts involved, the wallets and networks used, and the nationality of the user/customer, verification may need to be completed first. Where verification is triggered, the user/customer is required to provide identifying information, which may include: first name, last name, date of birth, country of usual residence, gender, and full address.
6. RISK-BASED VERIFICATION
Where triggered, verification may require a customer's ID check, confirmation of registered address, wallet ownership confirmation, and a source of funds/source of wealth check. Until any required verification is completed, withdrawals, tips, or deposits may be held. The customer may be asked to provide a picture of their ID. Depending on the country, the variety of accepted IDs may differ. An electronic check may verify that the data provided matches the submitted document and the name on the ID. If the electronic check fails or is not possible, the customer may be required to submit confirmation of their current residency, such as a certificate of registration from a government authority or a similar document.
7. CUSTOMER IDENTIFICATION AND VERIFICATION (KYC)
The formal identification of customers, where our risk-based approach requires it, is a vital element for both regulations related to money laundering and our KYC policy.
8. FUNDAMENTAL PRINCIPLES OF IDENTIFICATION
A copy of a passport, ID card, or driving licence may be required. Additionally, a second photo of the user/customer's face (a selfie) may be necessary. The customer may blur all information except for the date of birth, nationality, gender, first name, last name, and photo to secure their privacy. Please note that all four corners of the ID must be visible in the same image, and all details must be clearly readable except for the items mentioned above. We may request all details if necessary. An employee may perform additional checks if necessary, based on the situation.
9. PROOF OF ADDRESS
Proof of address may be required and can utilise different databases. If an electronic check fails, the customer has the option to provide manual proof. A recent utility bill sent to the registered address, or an official government document that proves the state of residence, may be required. To expedite the approval process, please ensure the document is submitted at a clear resolution with all four corners visible and all text readable. Acceptable documents include an electricity bill, water bill, bank statement, or any official correspondence from a government entity addressed to the customer. An employee may conduct additional checks if necessary based on the situation.
10. SOURCE OF FUNDS AND SOURCE OF WEALTH
Where a customer's cumulative deposits, withdrawals, or a single transaction reach a threshold set by the Website, or where activity is otherwise deemed higher-risk, a process is followed to understand the source of funds (SoF) and source of wealth (SoW). Examples of SoW include: ownership of a business, employment, inheritance, investment, or family. It is critical that the origin and legitimacy of the funds are clearly understood, which may include on-chain analysis of the originating wallet and the transaction history behind it. If this is not possible, an employee may request additional documentation or proof, and the account may be frozen pending review.
11. BASIC IDENTIFICATION DATA
Where required, basic identification data will be captured via the account settings page on the Website. This may include: first name, last name, nationality, gender, and date of birth. Records will be created and stored securely, and an employee may conduct additional checks if necessary based on the situation.
12. SCREENING
Sanctions & Politically Exposed Persons (PEPs): Sanction lists typically include individuals involved in organised crime, financial crime, terrorism, or those blocked for political reasons. The main aim of applying additional scrutiny to players classified as PEPs is to mitigate the risk of laundering the proceeds of bribery and corruption or assets stripped from their country of origin. While screening players, attention is paid to: match by name and surname (considering features of transliteration of names in different countries), date of birth (if available), gender, primary country, and appearance. Deposit and withdrawal wallets may additionally be screened against known lists of sanctioned, mixer-associated, or illicit-source addresses.
13. RISK MANAGEMENT
To address the various risks and levels of wealth in different regions, the Website categorises distinct risk regions and applies proportionate controls to each.
14. SANCTION LISTS COMPLIANCE
The following sanctions lists are strictly monitored and enforced, ensuring that no designated entities from these jurisdictions are engaged:
Consolidated List of Sanctions (EU)
UK Sanctions List and OFSI Consolidated List (UK)
DFAT Consolidated List (Australia)
United Nations Security Council Consolidated List (UN)
Specially Designated Nationals and Blocked Persons List (SDN) and Non-SDN Sanctions Lists (OFAC, U.S.)
Furthermore, sanctions lists are meticulously reviewed to ensure compliance with applicable regulations and to address any potential involvement with restricted entities. This includes assessing activities conducted within the designated restricted territories mentioned in the Website's Terms of Service, including all FATF blacklisted countries.
15. ADDITIONAL MEASURES
An automated monitoring system, overseen by the AMLCO, will monitor for unusual behaviour and report it to the Website's team. According to a risk-based approach and general experience, human employees will recheck the checks conducted by automated systems or other employees and may perform additional checks as needed. Automated and manual monitoring look for unusual behaviour such as: depositing and withdrawing without meaningful play sessions; attempts to route deposits and withdrawals through unrelated or high-risk wallets; changes in nationality, currency, network, or behaviour/activity patterns; and indications that an account is being used by someone other than its original owner. As a general rule, and to prevent money laundering, customers may be required to withdraw to the same wallet or method used to deposit.
16. ENTERPRISE-WIDE RISK ASSESSMENT
As part of its risk-based approach, the Website's team conducts an AML "Enterprise-Wide Risk Assessment" (EWRA) to identify and understand the risks specific to the Website's business lines. The AML risk policy is established after identifying and documenting the risks inherent to those business lines, including the services offered, the users served, the transactions performed, the delivery channels used, and the geographic locations of operations, customers, and transactions, together with other qualitative and emerging risks. The identification of AML risk categories is based on the understanding of regulatory requirements, expectations, and industry guidance. Additional safety measures are implemented to address the extra risks associated with online, cryptocurrency-based operations. The EWRA is reassessed periodically.
17. ONGOING TRANSACTION MONITORING
AML compliance ensures that ongoing transaction monitoring is conducted to detect transactions that are unusual or suspicious compared to the customer profile. This monitoring occurs on multiple levels:
First Line of Control: The Website works solely with trusted payment and settlement providers that have effective AML controls in place, and applies blockchain analytics to incoming and outgoing transactions to prevent the majority of suspicious deposits from occurring without proper due diligence.
Second Line of Control: The Website makes its network aware that any contact with a customer, player, or authorised representative must prompt due diligence on transactions associated with the account. This includes requests for executing financial transactions on the account and requests related to means of payment or services on the account. All transactions are overseen by employees supervised by the AMLCO, who is overseen by general management. Determining the unusual nature of one or more transactions depends essentially on an assessment related to the customer's known profile (KYC), their financial behaviour, and the transaction counterparty. These checks are conducted by automated systems, with an employee cross-checking for additional security. Any team member who observes an atypical transaction that cannot be attributed to lawful activities or known sources of funds must inform the AML division.
Third Line of Control: As a last line of defence, the Website's team conducts manual checks on suspicious and higher-risk users. If fraud or money laundering is identified, the relevant authorities will be informed.
18. TRAINING
The Website's team performs manual controls based on a risk-based approach for which they receive special training. The training and awareness program includes a mandatory AML training program in accordance with the latest regulatory developments for all employees in contact with finances, and induction AML sessions for all new employees. Content is established according to the type of business the trainees work for and their respective positions. These sessions are conducted by an AML specialist.
19. AUDITING
Internal audits regularly establish missions and reports concerning AML activities.
20. DATA SECURITY
All data provided by any user/customer is kept secure and will not be sold or shared with anyone else. Only if compelled by law, or to prevent money laundering, may data be shared with the relevant authority. The Website follows all guidelines and rules of the applicable data protection law.
21. CONTACT US
For any questions or complaints, communication is available via the email address specified in the Terms of Service.