Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.<\/p>\n
We will conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update customer information, using the customer risk profile as a baseline against which customer activity is assessed for suspicious transaction reporting.<\/p>\n
The main risk regarding money laundering and terror financing threats in this industry lies in the wallet-based model that most sales platforms in the industry use. A customer could, for example, deposit a certain amount of money using one payment method (like a credit card) and then later withdraw from his balance another amount, using a different method (such as a bank transfer).
\nIn order to prevent such abuses, we have established a number of safeguards:<\/p>\n
Player-to-player transactions are not possible due to our business model.<\/p>\n
We also block from making any kind of transaction on our website customers from countries listed on the EU\u2019s list of high-risk countries, which in its latest update from December 12th, 2023, includes the following countries: Upon signup, the customer is prompted to enter his email address. The customer will then receive a confirmation email with a verification link. By clicking that verification link, it is confirmed that the customer is the owner of that email account. Every month, the entire customer database will be re-checked against the sanctions, PEP and adverse media list, using namescan.io. Group 1<\/em><\/strong>: Customers with a transaction volume higher than \u20ac2000 per month, larger wins, or at least one single transaction of \u20ac500,00 or higher will automatically be flagged by our sales platform, and reported for manual revision by the AML Compliance Person. All cases (group 1, 2 and 3) that require Enhanced Due Diligence EDD will be included in a daily report for checking the customer\u2019s location, IP address, payment method and his transaction history. Also, all such customer accounts will also again be checked against a list of politically exposed persons (PEP), sanctions and adverse media list using namescan.io. The customer provides the firm with unusual or suspicious identification documents that cannot be readily verified or are inconsistent with other statements or documents that the customer has provided. Or, the customer provides information that is inconsistent with other available information about the customer. This indicator may apply to account openings and to interaction subsequent to account opening. When an employee of the firm detects any red flag, or other activity that may be suspicious, they will notify management. Management will determine whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, contacting the government, freezing the account and\/or filing a Suspicious Activity Report to law enforcement agencies (see $17).<\/p>\n When a customer wins an amount of up to \u20ac2000,00, that amount will be credited to his player wallet. All cases of winnings over \u20ac2000,00 will be reported immediately to management, and the customer will be checked against a PEP, sanctions and adverse media list using namescan.io. The following information will be stored for five years:<\/p>\n The five-year period will begin after the last purchase, last deposit, or last withdrawal activity of the customer in question We will develop ongoing employee training of senior management. Our training will occur on at least an annual basis. It will be based on our firm\u2019s size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law.<\/p>\n If a customer has committed a breach of terms and conditions, or a suspicion of illegal activity by a customer has been proven by our research beyond reasonable doubt, the customer account will be closed. The customer will be informed about such a closure by email.<\/p>\n All customer data for that customer will then added to a blacklist, with the effect that the customer be kept from creating a new account on our website using the same IP address, the same name or the same email address.<\/p>\n If a customer has been identified as being on either the sanctions list, PEP list or the adverse media list (by a search run via namescan.io) during any of the diligence actions (including the Customer Due Diligence described in \u00a74), the customer account will be blocked from any transaction on our website. Whenever a revision reveals suspicious activity, or activity of a person listed as a PEP, or activity of a person on a sanctions list, or a person on an adverse media list, all pertinent data will promptly be forwarded to the relevant authorities, such as the Financial Intelligence Unit.<\/p>\n In situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, we will immediately inform the appropriate law enforcement authorities, such as, but not limited to:<\/p>\n Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business. We will […]<\/p>\n","protected":false},"author":13,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_et_pb_use_builder":"","_et_pb_old_content":"","_et_gb_content_width":"","exclude_from_search":false,"footnotes":""},"class_list":["post-104932","page","type-page","status-publish","hentry"],"yoast_head":"\n
\nAfghanistan, Barbados, Belarus, Burkina Faso, Cameroon, Democratic Republic of the Congo, Gibraltar, Haiti, Iran, Jamaica, Mali, Mozambique, Myanmar, Nigeria, North Korea, Panama, Philippines, Russia, Senegal, South Africa, South Sudan, Syria, Tanzania, Trinidad and Tobago, Uganda, United Arab Emirates, Vanuatu, Vietnam, Yemen<\/em>
\nDeposits and purchases by any one single customer are limited to an amount of \u20ac1.000,00 per day, and \u20ac10.000,00 per month.
\nCustomers from the USA, Germany <\/em>and the Netherlands<\/em> are also blocked from making any kinds of transactions on our site.<\/p>\nCustomer due diligence, Signup procedure, General KYC Procedure<\/h2>\n
\nUpon making a ticket purchase, or a deposit into the player’s account, the player will be required to enter his\/her first an last name and his country of residence.
\nOnly private persons are allowed to sign up and purchase tickets through our website. Corporate entities are not accepted as customers, so that UBO checks are not necessary.
\nIt is not possible to create more than one account with the same email address.
\nNo customer is allowed to be represented by a third party or any type of representative.
\nPolitically Exposed Persons will not be allowed to make any kind of transactions or our website.<\/p>\nOngoing Due Diligence ODD<\/h2>\n
\nEvery three months, all customers will be contacted via email and asked to update their personal information, and given 7 days to either confirm that the information is up to date, or to edit their information. In case of any changes to the information, the necessary documents pertaining to that information have to be re-submitted by the customer.
\nIf any check against the sanctions, PEP or adverse media lists indicates that the information given by the customer does not correspond to the information from that list, the customer account will be blocked, a manual revision of the account data will be initiated, and the customer will be prompted to update his information and undergo a full, new KYC process, as described in \u00a74.
\nWe will monitor account activity for unusual size, volume, pattern or type of transactions, by taking into account risk factors and red flags that are appropriate and pertinent to our business.
\nOur sales platform will constantly check all purchases and transactions against set parameters such as amount of a single purchase, daily, weekly and monthly total volume. In cases where one of those parameters is exceeded, the customer account and the transaction in question will be flagged, and reported to our support staff as well as to the AML compliance person.<\/p>\n
\nAll customers of this group 1 will be required to provide information and documentation regarding their source of funds. While the manual revision is ongoing, they will be blocked from executing any further purchase or transaction on our website.
\nGroup 2<\/em><\/strong>: Customers from the countries listed in \u00a73 will be blocked from executing any transaction or purchase on our website.
\nGroup 3<\/strong><\/em>: Customers identified as signing up from the same IP address will be flagged for manual revision by our staff.<\/p>\n
\nIn cases where any of the abovementioned checks and revisions results in the suspicion of activity in breach of AML provisions, or activity related to terrorism financing, we will file a detailed report to the authorities dealing with such infractions.<\/p>\nPotential Red Flags in Customer Due Diligence and Interactions with Customers<\/h2>\n
\nThe customer is domiciled in a jurisdiction that is known as a high-risk geographic location (e.g., known as a narcotics-producing jurisdiction, known to have ineffective AML\/Combating the Financing of Terrorism systems) or conflict zone, including those with an established threat of terrorism.
\nThe customer maintains multiple accounts, or maintains accounts in the names of family members.
\nThe customer frequently changes bank account details or information for redemption proceeds, in particular when followed by redemption requests
\nFunds are transferred to financial or depository institutions other than those from which the funds were initially received, specifically when different countries are involved.
\nFunds are transferred into an account and are subsequently transferred out of the account in the same or nearly the same amounts, especially when the origin and destination locations are high-risk jurisdictions.
\nI all abovementioned cases (when a red flag is raised), Enhanced Due Diligence will be performed, as described in \u00a78.<\/p>\nResponding to Red Flags<\/h2>\n
Processing a win<\/h2>\n
\nWhen a customer wins an amount of more that \u20ac2000,00, our customer support will send the customer a claim form with his personal data, and his instructions regarding the pay-out of the winnings. To receive his payment, depending on the lottery, the customer can choose between a bank transfer, or a bank check. The customer will then also have to provide us with documents for identity verification:<\/p>\n\n
\nIf the revisions do not result in any suspicion, we will then forward those documents to the relevant lottery organization, and present them with the winning ticket on behalf of the customer.<\/p>\nInformation storing, Record Keeping<\/h2>\n
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\nWe will keep other documents according to other record keeping requirements.<\/p>\nStaff training<\/h2>\n
Sanctions<\/h2>\n
\nAll customer data for that customer will then added to a blacklist, with the effect that the customer be kept from creating a new account on our website using the same IP address, the same name or the same email address.<\/p>\nReporting<\/h2>\n
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