Anti-Money Laundering (AML) Policy Overview

1. Introduction

1.1 Understanding Money Laundering

Money laundering is any act intended to obscure or disguise the illegal origin of the funds, such as those from drug trafficking or terrorism, so as to make them appear legal. In other words, it is a way through which illegal funds or activities appear legal by changing their source, form, or location to avoid detection.

1.2 Overview of Anti-Money Laundering (AML)

Anti-Money Laundering (AML) refers to legal measures taken to avoid, detect, and report money laundering activities. The implementation of an AML program is a legal obligation to which all entities bound by the regulations are subjected; these include financial institutions. An AML program of such entities includes:

Criminalization of money laundering activities
Empower regulators and law enforcement with the right tools to investigate
This includes customer due diligence: requiring financial institutions to verify customer identity, carry out risk-based controls, keep records, and report suspicious activities.
Facilitate the sharing of information relative to specific cases with other jurisdictions.

2. Regulatory Obligations

Employees in the online gaming industry are required to report any information they encounter in their work if:

They have knowledge of potential money laundering or terrorist financing.
They become suspicious of such activities.
They have reasonable grounds to believe someone is involved in money laundering or terrorist financing.

This obligation is known as having grounds for knowledge or suspicion. Authorities expect organizations to provide evidence that a thorough risk assessment was conducted before establishing business relationships. Adequate measures must be in place to ensure that client transactions align with the identified level of risk.

Organizations must also show that ongoing monitoring is conducted in accordance with risk sensitivity and that adequate records are maintained to support a precise risk profile. This policy outlines further measures for risk monitoring, including the requirement for clients to disclose the source of their funds in high-risk situations.

2.1 Special Requirements

The organization is irrevocably committed to integrating compliance within all levels of its operation, more so concerning Curaçao gaming licenses that stipulate the playing of online games of chance.

3. AML Policy on Crime and Disorder

The AML policy adheres to core principles and practices, including:

Equipping designated officers with the resources and authority necessary to act independently and effectively
Establishing effective systems and controls that align with legal and regulatory requirements.
Conducting annual risk assessments to adopt a flexible, effective, proportionate, and cost-efficient risk-based approach.
Securing full commitment from senior management to support the Anti-Money Laundering (AML) policy.
Regularly assessing the adequacy of existing systems and controls.
Keeping transaction records that fulfill law enforcement requirements for investigating money laundering and terrorist financing.
Providing initial and ongoing training for all relevant employees to ensure compliance and awareness.

4. Risk Management

Our risk assessment and management strategies and procedures comply with the 2007 Money Laundering Regulations. The following actions are included in this risk-based approach:

determining the particular dangers of terrorist funding and money laundering that apply to the organization.
creating and putting into implementation suitable policies and processes to efficiently control and lessen these risks.
continuously assessing and enhancing these controls’ efficacy.
recording the steps done and the justification for them.

This approach, which has the full support of senior management and the active engagement of every employee, guarantees that resources are directed where they are most needed, optimizing overall effectiveness. We have carried out a comprehensive business risk assessment for money laundering, evaluating possible risks as well as the effects they may have.t from senior management and active cooperation from all employees. A comprehensive business risk assessment for money laundering has been conducted, considering both threats and their potential impact.

5. Suspicious Activity

Transactions or player profiles that trigger red flags, including mismatched deposits, are considered suspicious conduct. The organization provides specific examples to help identify such activities and outlines when to apply enhanced due diligence, which may require:

Bank statements
Passport or ID card
Utility bills

EDD assesses the risk level of players, with monitoring and further inquiries initiated when specific conditions are met. This may involve evaluating a customer’s place of work, the value of their home, and whether these are consistent with their spending patterns.

5.1 Operational Process

The organization reviews player spending and activity to identify suspicious behavior before processing any withdrawals. Procedures include:

The checking of the customer’s deposit history for no suspicious payments.
Ensuring appropriate customer turnover, which is derived from their activity within the casino, not solely in respect to moving funds in and out of the account.
Returning funds, whenever possible, to the original payment method used by the customer

5.2 Suspicious Activity Reports (SARs)

Under this policy, suspicious Activity Reports or SARs are essential. In any belief or suspicion that a person or customer is involved in money laundering or terrorist financing, it is to be reported to the risk team by the employee. Failure to report suspicions may lead to criminal charges.

The SARs are to be treated as fully confidential; where possible, hand-written and not via e-mail in order to maintain privacy. In no case is the staff to discuss any AML-related issues with the individual under investigation or any third party. This would amount to “tipping off” and is a serious offense. No comments on customer accounts should be made indicating suspicion of money laundering because at any time, customers can demand full access to their account notes.5.3 Escalation Process
Escalating suspicious activity is essential to protect the company from financial risk and ensure compliance with regulatory standards across jurisdictions. Any activity that appears suspicious, no matter how minor, must be addressed. Failing to act on suspicions of money laundering can result in criminal prosecution.

6. Employees

6.1 Senior Management

Senior management is ultimately in charge of carrying out this policy and could be held liable for any violations or omissions made in accordance with the Regulations.

6.2 Money Laundering Reporting Officer (MLRO)

The appointed MLRO tries to prevent and detect money laundering and find terrorist financing in accordance with the Crimes Act 2000. The MLRO appointed is Nikos Lajos, reachable at finance@pinupbangladesh.casino or +35780077001, who also manages the SARs in its systems but more so those based in Malta.

The MLRO’s key responsibilities include:

Keeping senior management informed about Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) efforts
Handling employee disclosures in line with Part 7 of the Crimes Act 2002 (POCA) and Part III of the Terrorism Act 2000
Submitting external reports when necessary

The MLRO is granted the autonomy to carry out duties independently and is provided with the necessary resources to perform this role effectively.

6.3 Employee Training

Every employee is required to complete training in order to comprehend their reporting responsibilities regarding money laundering and the function of the MLRO. This training ensures employees are familiar with the procedures for escalating suspicious incidents and are aware that failure to comply with legal requirements, including monitoring for criminal activities, may lead to criminal or regulatory consequences.

The training covers essential topics, including:

Procedures for reporting suspicious activities to the appropriate authorities, obtaining necessary consents for gaming participation, and conducting business transactions
Customer Due Diligence (CDD), with enhanced requirements for high-risk clients, including Politically Exposed Persons (PEPs)

7. High-Risk Jurisdictions

High-risk jurisdictions are those identified by the Financial Action Task Force (FATF) or recognized by the Gambling Commission. Customers registered in these high-risk areas are subject to Enhanced Due Diligence (EDD) procedures.

The current countries on the FATF list include:

Afghanistan
Bosnia and Herzegovina
Ecuador
Guyana
Algeria
Angola
Iraq
Myanmar
Lao PDR
Panama
Uganda
Yemen
Papua New Guinea
Syria
Iran
North Korea

8. Record Keeping

We maintain thorough records to assist with any financial investigations conducted by law enforcement. Our record-keeping policies include:

Reports to senior management from designated officers
Assigning specified officers AML/CTF tasks
Documentation explaining why no further action was taken when applicable
Internal and external Suspicious Activity Reports (SARs)
The designated authority’s monitoring of compliance
Records of business relationships or occasional transactions
Customer identification and verification details
Employee training logs

9. Criminal Offenses

All employees are informed of their responsibilities regarding the following offenses:

Under the Proceeds of Crime Act (POCA) and the Terrorism Act, it is a criminal offense to fail to report suspicious activities.
Under POCA and the Terrorism Act, it is also an offense to disclose information that could jeopardize an investigation, including details related to Suspicious Activity Reports (SARs).
An employee will be found to have acted with blameworthy mental state and liable when they knowingly falsify, conceal, destroy or dispose of any information relevant to a continuing investigation knowing or having reason to know that the appropriate authority is acting or about to act on it.
Failure to report suspicious activities to the NCA or a nominated officer as soon as practicable may lead to a criminal prosecution.

10. Employee Screening Procedures

The Company undertakes thorough background checks during the recruitment process for confirming that a new employee is at least of the statutory age and for verifying identity and credentials from at least two independent references. Additional information of a personal or background nature may also be verified in this process.

11. Protecting Company Assets from Internal and Criminal Misuse

The company has implemented rigorous processes and controls to safeguard their most valuable assets against fraud and theft. Some of the policies introduced within our organizations against this are secured server equipment located in Unicept Malta, which is supported by policies such as visitor management process, fire alarms, document shredding, locked cabinet policies, security teams and periodic testing.

Moreover, all our office merchants also adhere to these protection policies.

12. Compliance and Risk Committee

We will be creating a Compliance and Risk Committee; this committee shall be charged with the oversight of executive risks. Members shall include the MLRO, one Compliance Officer, and one additional non-executive director. Meetings shall be once every quarter or as frequently as may be required.

13. Working with Trustworthy and Reputable Companies

The merchant operates business at every level in accordance with the highest standards of business ethics. In supplier selection, the company seeks the following:

Stability for long-term financial commitments
Actions to implement broad corporate responsibility programs
Conformity to all legal and regulatory requirements
Capacity and commitment to provide quality and value

There is a rigorous approval process for new suppliers, in which all information put forward by them has to be duly verified. The trader also evaluates the risk factors of the supplier, more so above criteria. Suppliers who fail the examination will be duly informed that they have not succeeded. That all organizations and persons entering into contracts with us within the relevant jurisdiction fully understand their compliance obligations.ions.

14. Responsibilities under the Crimes Act (POCA)

The business is fully conversant with the procedures and policies necessitated under the Proceeds of Crime Act 2002, and all measures are in place to ensure compliance.

15. Internal Record Keeping

Key principles for internal record-keeping include:

Retention of customer information records for at least a period of six years from the date of the end of the customer relationship, without regard to any account status or value status.
Retain a record of all customer transactions for at least six years from the date of the transaction.
Maintain a record of money laundering investigation and suspicious activity reporting six years from the date of completion of the investigation.

16. Collusion Prevention and Data Protection Compliance

To this end, the terms and conditions of the company maintain that it does not condone fraudulent activities and that customers’ accounts found to have been involved in such deals will be closed.

In addition, with Payment IQ, it ensures data security since all payment account information of users are kept, encrypted, and maintained within the system, with no permission given to access it by the employees of the merchant. Customer information is guarded through the information security policy that involves controls for system access and authentication, password policies, malware protection, intrusion prevention measures, encryption, and strict network management.

Know Your Customer (KYC) Policy Overview

Introduction

By accepting our Terms, you hereby grant us permission to perform such verification checks as may be necessary, in form and substance satisfactory to us in our discretion, to confirm your identity and contact information (“Checks”) as we may require or as may be required by third parties, including without limitation regulatory bodies. We may limit your ability to withdraw Available Funds in your Account while we conduct Checks.

If we find that the information provided by you misrepresents a false, inexact, or misleading statement against your ID, partial, or incomplete, we reserve all rights to immediately terminate your account and/or restrict access to our Services, including any other action which may be deemed appropriate.

Also, we reserve the right to suspend your account if we are unable to verify that you are of the required minimum age. In the event of such a finding, if it comes to our notice that at the time of any gaming or gambling transaction you were under-age, we will take the following steps:

Your account will be closed.
All transactions during such a period will be made void, and your funds deposited will be returned.
Any winnings accrued in this time frame will be voided, and you will be required to repay any money that you have withdrawn from your account.

You need to inform our support team immediately when any of the details concerning your personal information change in order for us to update it correctly.

Policy Objective

The Company will require verification from users of its Services under the following circumstances:

When there is suspicion of fraud, money laundering, or other criminal activities.
If there are concerns about the authenticity of the documents submitted.
In cases where the Company’s Terms of Use have been violated.
In any other situation that the Company considers appropriate.

The verification process may involve requesting a standard set of identification data and documents, as well as any additional documentation deemed necessary.

Minimum Required Identity Information:

Complete name
Birthdate
Country of origin
Permanent home address
A unique identifying number

Essential Documents:

An authentic ID card or passport
documents (such a utility bill or bank statement) attesting to the customer’s permanent address at the specified time

Additional Documents That May Be Requested:

A secondary national ID (e.g., driver’s license, military ID)
A photograph of the user holding their open passport with their face clearly visible in the background (the document must be legible)
A photo of the front of the user’s bank card, showing the first 5 and last 4 digits, the owner’s name, and the expiry date

Furthermore, the Company may require documentation verifying the source of funds to ensure that the User provides clear evidence of where the funds used for betting or gaming originated. This documentation may include:

Dated proof that an award or payment was provided to the user.
Proof of Income: payslip, director’s remuneration, dividends, or pension.
An original deed of trust showing clearly an entitlement to the funds.
A bank statement or savings account showing steady deposits from a traceable source.

Document Verification Process:

The Company will carefully review the documents provided to ensure:

The name and address on the documents match the account details
The documents are legitimate and not counterfeit
The documents meet requirements for ID verification (e.g., an actual utility bill rather than an envelope)
No discrepancies are found by Company staff or contractors

Based on the document analysis, the Company will make a decision in accordance with its terms and conditions, privacy policy, license agreements, and legal obligations.

Responsibility and Liability

Due Diligence (DD)

All customers of the Company shall go through a Due Diligence (DD) process that is to be performed in conformity with the data protection regulations.

Benami Accounts

Accounts that bear the name of a person other than the owner of the account are termed as Benami accounts and such accounts are not acceptable. If, for any reason, an account is found to be an alias, or if the identity of the account holder is disputed or uncertain, Due Diligence will be conducted with all due speed to verify the authenticity and validity of the account holder’s identity. If the identity of the account holder cannot be verified, the account will be closed, any winnings voided, and deposits either returned to the original account or withheld, whichever applies.

Dual/Multiple Accounts

Some customers may open several accounts in order to independently record different gambling expenses. Regardless of such actions, the Company will identify and link the customer’s accounts. The Company reserves the right, at its sole discretion, to close any duplicate accounts, void any winnings accrued through duplicate accounts, and refund all funds deposited back to the customer account.

Politically Exposed Persons (PEPs)

The Company shall give the most careful consideration to any person qualifying as a Politically Exposed Person, meaning a person holding or having held during the last year a prominent public position or a position providing influence over public funds or access to them. PEPs also include close family members and associates of these persons. This would be taken forward using a risk-based approach depending on value, size of gambling, and jurisdiction. The nature of the customer’s KYC shall involve questions indicating whether they are PEPs or not.