POLICY OF COMBATING MONEY LAUNDERING (AML)

1. INTRODUCTION

Betinbet undertakes to fulfill all national and international obligations to combat money laundering (AML) and prevent the financing of terrorism (CTF).

Money laundering refers to the transfer of income obtained from illegal means to the legal financial system and is a crime.

2. Purpose

This policy aims to provide:

  • Combating money laundering and the financing of terrorism
  • Timely detection of suspicious activities
  • Compliance with legal obligations
  • Recording of all transactions in an auditable manner
  • Awareness and reporting training of the staff

3. LEGAL FRAMEWORK

Betinbet acts in accordance with the laws of Curacao and international regulations (e.g. FATF, EU 5AMLD, POCA 2002).

The Company accepts the obligation to submit reports to the authorized institutions, share data and prevent suspicious activities.

4. KYC / CDD PROCESS

All users must submit the following information in full:

  • Identification papers
  • Proof of Address
  • Fund Source (if needed)

Improved due diligence (EDD) is mandatory for high-risk users, large money movements or high-risk countries.

5. SUSPICIOUS ACTIVITIES (SAR)

If a suspicious procedure is detected:

  • The process is frozen
  • SAR (Suspicious Activity Report) is prepared
  • Reported to MLRO (AML Responsible) and/or official institutions
  • This process is confidential, the relevant player is never informed ("tip-off" ban)

6. AML CONTROLS

The following are constantly followed:

  • Frequency and amounts of deposits
  • Betting behavior and play rates
  • Withdrawal requests
  • IP, device, country exchange
  • Whether the funds are legitimate

Withdrawals cannot be made without AML examinations.

7. STAFF RESPONSIBILITY and TRAINING

  • All employees are trained on AML.
  • It is obliged to report suspicious situations to MLRO.
  • Employees who do not report also fall under criminal responsibility.
  • Transactions related to all AML processes are kept under record for 6 years.

8. HIGH RISK COUNTRIES

Users from high-risk areas defined by the FATF are subject to special review (EDD).

These countries include: Afghanistan, Iran, North Korea, Myanmar, Syria, Panama, Uganda, Yemen and others.

Users who apply from these countries will be rejected from the system.

9. PRIVACY & DATA PROTECTION

Data obtained in AML processes:

  • Accessible only by authorized personnel
  • Encrypted stored in secure systems
  • Shared with legal units only when necessary

10. SYSTEM SECURITY

Our servers are managed in accordance with international security policies.

Visitor access, authentication, password management, network control and measures against malware are applied.

11. COMMITMENT

Betinbet, in order to prevent money laundering:

  • Regularly reviews AML Policies
  • Risk Committee holds meetings
  • Evaluates third parties and suppliers in terms of AML
  • AML immediately closes accounts in case of suspected breach