Our intention is to provide the highest level of security to all visitors and customers of the Website. To that end, a two-step verification mechanism is employed in order to ascertain the identity of our customers. The purpose of this mechanism is to confirm that the particulars supplied by the registered individual are accurate and that the deposit instruments used have neither been stolen nor appropriated by another party. Our objective is to lay down a general framework for the prevention of money laundering. We further recognize that, depending upon nationality and country of origin, distinct safety measures may need to be adopted in respect of payment methods and withdrawals.

In parallel, the Website’s team puts in place reasonable measures to manage and contain money-laundering (ML) risk, including the allocation of suitable resources to that end.

Money laundering shall be construed as encompassing the following:

• the conversion or transfer of property - particularly money - where the person concerned knows that the property is the proceeds of criminal activity or of participation in such activity, and acts with a view to disguising or concealing the unlawful origin of the property, or to assisting any person engaged in such activity to evade the legal consequences of that conduct;
• the concealment or disguise of the true nature, source, location, disposition, movement, rights attaching to, or ownership of property, where the person concerned knows that the property is the proceeds of criminal activity or of participation in such activity;
• the acquisition, possession, or use of property, where the person concerned knows at the moment of receipt that the property was obtained through criminal activity or through assistance rendered to such activity;
• involvement in, association for the purpose of committing, attempts to commit, and the aiding, abetting, facilitating, or counselling of any of the conducts described in the preceding paragraphs;
• money laundering shall be treated as such even where the underlying conduct that generated the property to be laundered was carried out within the territory of another Member State or of a third country.

The AML Compliance Officer (AMLCO) is entrusted with the enforcement of the AML policy and procedures throughout the system.

The AMLCO reports to, and operates under the direct authority of, general management.

Every material amendment to the Website’s AML policy shall be subject to approval by both general management and the AMLCO.

Every user and customer is required to complete verification in order to withdraw funds. The verification must be carried out beforehand, having regard to the payment method selected, the amount paid in or to be withdrawn, the withdrawal channel chosen, and the nationality of the user or customer. Step one of verification consists of a document to be completed by the user or customer in person; the particulars to be supplied include first name, last name, date of birth, country of habitual residence, gender, and full address.

The process may involve a check of the customer’s ID, confirmation of the registered address, a Source of Funds enquiry, and so forth.

Until the two-step verification has been completed, withdrawals, tips, and deposits shall be placed on hold. The customer is required to submit a photograph of their ID; the range of acceptable IDs may differ from one country to another. An electronic check then verifies that the data entered at step one matches the document supplied and the name shown on the ID. Should the electronic check fail, or prove impracticable, the customer shall be required to provide confirmation of their current residence, in the form of a registration certificate issued by a government authority or a comparable document.

The formal identification of customers at the time of entering into commercial relations constitutes a vital element both of the regulations governing the prevention of money laundering and of the present KYC framework.

The Website observes and aligns with the “Know your customer” (KYC) framework, the purpose of which is to deter financial crime and money laundering by means of client identification and due diligence.

At any moment, the Website may request whichever KYC documentation it considers necessary in order to establish the identity and location of any user of the Website. We retain the right to limit service provision, payments, or withdrawals until the user’s identity has been adequately confirmed, or for any other ground at our sole discretion in accordance with the applicable legal framework.

Our approach is risk-based, and we carry out rigorous due diligence reviews along with continuous monitoring of every client, customer, and transaction. In accordance with the anti-money-laundering regulations, three tiers of due diligence checks are applied, the choice depending on the risk profile, the transaction, and the type of customer.

SDD - Simplified Due Diligence applies to cases of very low-risk transactions that fall short of the applicable thresholds 

CDD - Customer Due Diligence represents the standard level of diligence checks, employed in the majority of cases for the purposes of verification and identification 

EDD - Enhanced Due Diligence applies to higher-risk customers, sizeable transactions, or particular circumstances. 

Independently of, and in addition to, the foregoing, where a user accumulates lifetime deposits totalling in excess of EUR 2,000, submits a withdrawal request for any sum within the Website, or attempts or carries out a transaction regarded as suspicious, completion of the full KYC procedure becomes mandatory for that user.

A copy of the user’s passport, ID card, or driving licence may be required. In addition, a separate photograph showing the user or customer’s face may be requested. With a view to preserving privacy, the customer is at liberty to mask all details appearing on the document save for the date of birth, nationality, gender, first name, last name, and photograph.

All four corners of the ID document shall be visible within a single image, and every detail shall be plainly legible save for the items mentioned above. Where necessary, the disclosure of all details may nonetheless be requested.

In practical terms, the verification materials to be furnished by the user comprise the following:

• A copy of a government-issued photographic identification (occasionally including both front and reverse sides, depending upon the type of ID document);
• A self-portrait photograph of the user while holding the said ID document;
• Documentary proof of residence (for example, a bank statement or utility bill).

Each of the foregoing documents shall satisfy the following conditions:

• The full name shown corresponds to the user’s name
• The documents retain a remaining validity of more than 3 months
• The document holder is above 18 years of age

An employee may carry out additional checks where the circumstances so warrant.

Proof of address may be required and may draw upon a variety of databases. Where the electronic check is unsuccessful, the customer has the option of furnishing manual proof.

A recent utility bill addressed to the registered address of the customer, issued within the last 3 months, or an official government document evidencing the customer’s state of residence, may be requested.

In order to expedite approval, the document should be supplied at a clear resolution, with all four corners visible and all text legible.

By way of example, acceptable documents include an electricity bill, a water bill, a bank statement, or any official correspondence from a government authority addressed to the customer.

An employee may carry out further checks where the circumstances so warrant.

Where a player deposits in excess of five thousand euros, a process is undertaken in order to ascertain the source of wealth (SoW).

Examples of SoW include:

• Ownership of a business
• Employment
• Inheritance
• Investment
• Family

It is essential that the origin and lawfulness of the wealth concerned be clearly established. Where this proves impracticable, an employee may request additional documentation or supporting evidence.

The account will be frozen where the same user deposits the aforesaid amount in a single transaction, or by way of multiple transactions whose aggregate equals or exceeds that amount.

The basic document is accessible from the settings page on the Website. Each user is required to complete the following details:

• First name
• Last name
• Nationality
• Gender
• Date of birth

The document is generated and stored by AI, and an employee may carry out additional checks where the situation so requires.

Where the KYC procedure does not succeed, the cause is recorded and a support ticket is opened within the system. The ticket reference number, together with an explanation, is subsequently conveyed to the user.

Upon receipt of all the requisite documents on our side, the account is duly approved.

Sanctions and Politically Exposed Persons (PEPs): sanction lists ordinarily comprise individuals associated with organized crime, financial crime, or terrorism, or who are subject to restrictions on political grounds. The principal aim of applying additional scrutiny to players classified as PEPs is to mitigate the risk of laundering the proceeds of bribery and corruption, or of assets stripped from their country of origin. In the course of screening players, attention shall be paid to the following:

• Match by name and surname (with due regard to the transliteration of names across different countries)
• Date of birth (where available)
• Gender (male/female)
• Primary country
• Appearance

In order to address the various risks and disparate levels of wealth across regions, the Website categorizes distinct risk regions.

The sanctions lists set out below are strictly monitored and enforced, with the result that no designated entities from those jurisdictions are engaged with:

• 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.)

Sanctions lists are, in addition, examined with care so as to ensure compliance with the applicable rules and to address any potential involvement with restricted entities. This includes the assessment of activities conducted within the restricted territories identified in the Website’s terms of service, including every FATF-blacklisted country.

The country indicated on the identification and proof-of-residence documents shall accordingly not feature among the restricted jurisdictions listed in the Website’s terms of service, which include every FATF-blacklisted country.

An AI system, overseen by the AMLCO, monitors for unusual behaviour and reports any instance thereof immediately to the Website’s team.

In keeping with a risk-based approach and general experience, human employees re-examine every check previously carried out by the AI or by other employees, and may perform additional checks where required.

In addition, a data scientist, supported by modern electronic analytical systems, monitors for unusual behaviour such as the following:

• Depositing and withdrawing in the absence of longer betting sessions
• Attempts to use different bank accounts for deposits and withdrawals
• Changes in nationality, currency, or behavioural and activity patterns
• Verification that an account is being used by its original owner

Users must employ the same method for withdrawal as that used for the initial deposit, in order to prevent any money laundering.

As part of its risk-based approach, the Website’s team has carried out an AML “Enterprise-wide Risk Assessment” (EWRA) in order to identify and understand the risks specific to the Website’s team and its business lines. The AML risk policy is established by reference to the risks inherent in those business lines, including the services provided, the users served, the transactions effected by those users, the delivery channels employed, the geographic locations of operations, the customers, the transactions, and other qualitative and emerging risks.

The identification of AML risk categories is grounded in an understanding of regulatory requirements, supervisory expectations, and industry guidance. Additional safety measures are deployed to address the further risks associated with the World Wide Web.

The EWRA is reviewed annually.

AML compliance entails ongoing transaction monitoring designed to detect transactions which are unusual or suspicious relative to the customer profile. Such monitoring is carried out on two levels:

First Line of Control

The Website works solely with trusted Payment Service Providers having effective AML policies in place, so as to prevent the majority of suspicious deposits from being processed in the absence of proper KYC procedures applied to potential customers.

Second Line of Control

The Website ensures that its network is aware that any contact with a customer, a player, or an authorized representative shall trigger due diligence on transactions associated with the account. This includes:

• Requests for the execution of financial transactions on the account;
• Requests concerning means of payment or services on the account.

In addition, the two-step verification process, together with adjusted risk management, shall at all times provide all necessary information regarding all customers of the Website. All transactions are supervised by employees, who are themselves supervised by the AMLCO; the AMLCO is, in turn, supervised by general management.

Specific transactions referred to the customer support manager, where appropriate via the Compliance Manager, shall likewise be subjected to due diligence.

The determination as to whether one or more transactions are unusual rests essentially on a subjective assessment having regard to the customer’s profile (KYC), their financial behaviour, and the transaction counterparty.

These checks are carried out by an automated system, with an employee performing cross-checks for additional security.

Transactions observed on customer accounts in respect of which a satisfactory understanding of the lawful nature of the activity and the origin of the funds cannot readily be obtained shall be regarded as atypical (since they are not directly justifiable).

Every team member of the Website is required to inform the AML division of any atypical transactions which they identify and which cannot be attributed to a lawful activity or to a known source of income of the customer.

Third Line of Control

As a final line of defence against AML, the Website’s team shall conduct manual checks on every suspicious and higher-risk user, with a view to comprehensively preventing money laundering.

Where fraud or money laundering is identified, the authorities will be notified.

The Website’s team shall carry out manual controls on the basis of a risk-based approval process, in respect of which they shall receive specialized training.

The training and awareness programme will include:

• A mandatory AML training programme aligned with the most recent regulatory developments, for all employees coming into contact with finances;
• Academic AML learning sessions for all new employees.

The content of the training programme is determined in light of the type of business in which the trainees are engaged and their respective positions. These sessions are conducted by an AML specialist.

Internal audits shall, on a regular basis, establish missions and produce reports concerning AML activities.

All data supplied by any user or customer shall be kept secure and shall neither be sold nor shared with any third party. Save where compelled by law, or where required for the prevention of money laundering, data may be shared with the relevant AML authority.

The Website shall comply with all guidelines and rules of the applicable data protection legislation.

For any questions or complaints, communication is available by email, the address of which is set out in the Terms of Service.