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Anti-Money Laundering Policy

Definition of Money Laundering
Money laundering is understood as:
  • The conversion or transfer of property, especially money, knowing that such property is derived from criminal activities or participation in such activities, with the aim of concealing or disguising the illegal origin of the property or helping any person involved in these activities to avoid the legal consequences of their actions or companies.

  • The concealment or disguise of the true nature, origin, location, disposition, movement, rights to, or ownership of property, knowing that such property is derived from criminal activities or from participation in such activities.

  • The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activities or aiding such activities.

  • Participation, association to commit, attempts to commit, and aiding, abetting, facilitating, and advising the practice of any of the actions mentioned above.

Money laundering shall be considered as such even when the activities that generated the property to be laundered were carried out in the territory of another Member State or a third country.

Risk Management

Additional Measures
In addition, an AI supervised by the anti-money laundering compliance officer will seek out any unusual behavior and report it immediately to an employee at

In accordance with a risk-based approach and general experience, human employees will review all controls previously made by the AI or other employees and may redo or perform additional checks according to the situation.

Enterprise-wide Risk Assessment
As part of its risk-based approach, has conducted an “Enterprise-wide Risk Assessment” (EWRA) to identify and understand the specific risks of and its lines of business. The AML risk policy is determined after identifying and documenting the inherent risks in its lines of business, such as the services offered by the site. The users to whom the services are provided, transactions carried out by these users, delivery channels used by the bank, geographical locations of the bank’s operations, customers and transactions, and other qualitative and emerging risks.

The identification of AML risk categories is based on’s understanding of regulatory requirements, regulatory expectations, and industry guidelines. Additional security measures are taken to address the additional risks that the internet brings.

The EWRA is reassessed annually.

Continuous Transaction Monitoring
AML compliance ensures that “continuous transaction monitoring” is conducted to detect unusual or suspicious transactions compared to the customer’s profile. This transaction monitoring is conducted at two levels:

1) The First Line of Control exclusively works with trusted Payment Service Providers, all of whom have effective AML policies to prevent the vast majority of suspicious deposits at from occurring without proper execution of KYC procedures on the potential client.

2) The Second Line of Control makes its network aware so that any contact with the customer, player, or authorized representative triggers due diligence on transactions in the account in question. These include:

  • Requests for the execution of financial transactions in the account.
  • Requests related to means of payment or services in the account.

Additionally, a three-step verification with adjusted risk management should provide all necessary information about all clients of at all times.

Furthermore, all transactions must be overseen by employees supervised by the AML compliance officer, who is overseen by the general management. Specific transactions forwarded to the customer support manager, possibly via their Compliance Manager, should also be subject to due diligence.

Determining the unusual nature of one or more transactions depends on a subjective assessment, with respect to the customer’s knowledge (KYC), their financial behavior, and the counterparty of the transaction.

These checks will be performed by an automated system, while an employee reviews them for additional security. Transactions observed in customer accounts for which it is difficult to gain a proper understanding of the legal activities and origin of funds should be quickly considered as atypical (as they are not directly justifiable).

Any member of the team should report to the AML division on any atypical transactions they observe and cannot attribute to a legal activity or known income source by the client.

3) The Third Line of Control
As the last line of defense against money laundering, will conduct manual checks on all suspicious and high-risk users to prevent money laundering completely. If fraud or money laundering is found, authorities will be notified.

Reporting of Suspicious Transactions at

In their internal procedures, describes in precise terms, for the attention of their team members, when it is necessary to report and how to proceed with such a report.

Reports of atypical transactions are reviewed by the AML team according to the precise methodology fully described in the internal procedures. Depending on the outcome of this analysis and based on the information collected, the AML team:

  • Will decide whether or not to file a report to the UIF, in accordance with the legal obligations provided in the Law of September 18, 2017.
  • Will decide whether or not to terminate business relationships with the customer.

Human employees of will perform manual checks based on risk-based approvals for which they will receive special training. The training and awareness program is reflected by its use:

  • A mandatory AML training program according to the latest regulatory developments for all involved in finance.
  • AML learning academic sessions for all new employees.

The content of this training program should be established according to the type of business the trainees are working for and the positions they hold.

Internal audit regularly sets missions and reports on AML activities.

Data Security
All data provided by any user/client will be kept secure and will not be sold or provided to anyone else. Only if required by law, or to prevent money laundering, may data be shared with the AML authority of the affected state. will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC).

Contact Us
If you have any questions about our AML and KYC Policy, please contact us:

If you have any complaints about our AML and KYC Policy or about the checks made on your account and on you personally, please contact us: