AML/KYC Policy

I. INTRODUCTION

This anti-money laundering (AML) and know your customer (KYC) policy that is applicable to all staff to help prevent and detect potential money laundering or terrorist financing activity. The Company takes a zero-tolerance approach to money laundering, terrorist activity and other such financial crimes.

Mi7eu.bet (hereinafter referred as “Mi7eu.bet” or “Company”) will actively participate in preventing the services of the Company from being exploited by criminals and terrorists for money laundering or terrorist financing purposes. The objectives of this policies are:

  • ensuring the Company’s compliance with all applicable laws, statutory instruments of regulation, and requirements of the Company’s supervisory body;
  • protecting the Company and its staff as individuals from the risks associated with breaches of the law, regulations and supervisory requirements;
  • preserving the good name of the Company against the risk of reputational damage presented by implication in money laundering and terrorist financing activities;
  • making a positive contribution to the fight against crime and terrorism.

1.1 ANTI-MONEY LAUNDERING

Money Laundering is the process of creating the appearance of funds obtained from criminal activity, being originated from a legitimate source. Criminals attempt to launder money by disguising the source and/or changing the form of the funds, or moving them to a place where they are less likely to attract attention.

Anti-money laundering (AML) is a term used to describe the legal controls that require financial institutions and other regulated entities to prevent, detect, and report Money Laundering activities.

An effective AML program requires a jurisdiction:

  • to have criminalized Money Laundering;
  • to have given the relevant regulators and police the powers and tools to investigate it;
  • to have its institutions identify their customers, establish risk-based controls, keep records and report suspicious activities;
  • to be able to share information with other jurisdictions as appropriate.

2. REGULATION

Employees working in the remote gaming industry are required to make a report in respect of information that comes to them in the course of their business:

  • when they know;
  • when they suspect;
  • when they have reasonable grounds for knowing or suspecting that a person is engaged in money laundering or terrorist financing, including criminal spend.

These obligations are collectively referred to as grounds for knowledge or suspicion. What the authorities are looking for is that we are able to demonstrate, with supporting evidence, that a risk assessment is and has been undertaken prior to entering into business relationships with customers and that adequate customer due diligence is conducted in order to ensure that customers’ transactions are consistent with the level of risk presented.

In this document, we have identified measures that are being applied in order to carry out risk monitoring and the need of where we would require a Declaration of the source of funds from customers in situations which present a high risk and potentially money laundering.

3. AML POLICY PRINCIPLES

AML policy is based on principles and practises:

  • we develop systems and controls that are appropriate for our businesses and comply with legal and regulatory requirements;
  • we assess the AML risks inherent in our current business at least annually; we then adopt a risk-based approach that is flexible, effective, proportionate and cost effective;
  • we have full commitment for this from, and responsibility resting with, senior management;
  • we regularly assess the adequacy of our systems and controls;
  • we maintain, where necessary, records of transactions that meet the needs of law enforcement investigations tackling money laundering and terrorist financing;
  • we provide initial and ongoing training for all relevant employees.

4. RISK MANAGEMENT

We have a policy and procedures in relation to risk assessment and management, as required under the Money Laundering Regulations (the Regulations). This risk-based approach involves a number of discrete steps in assessing the most proportionate way to manage and mitigate the money laundering and terrorist financing risks we face:

  • identify the money laundering and terrorist financing risks that are relevant to us;
  • design and implement policies and procedures to manage and mitigate these assessed risks;
  • monitor and improve the effective operation of these controls;
  • record what has been done, and why.

5. SUSPICIOUS ACTIVITY

Suspicious Activity in this case is being referred to as suspicious transactions, extreme player profiles, when deposits are not matching up amongst other elements. Other concrete examples of how we identify players who require our team to undertake a risk monitoring approach of our customers and when to specifically carry out enhanced due diligence checks on the Player

Profiles can be further required:

  • Passport or ID card;
  • Utility bill;
  • Bank statement;
  • Any other proof of identity.

The Enhanced Due Diligence Checks are subject to players’ profile and the amount of Risk they pose to us. Only when we determine some of the above points or a combination of a few will we flag the customer/customers in question and conduct risk monitoring.This will include checks of where the customer works, value of his/her real estate or other property, where the customer lives and checks to see whether the value of the house is logical compared to the customers spending.

5.1 Suspicious Activity Reports SARs

Within that framework, Suspicious Activity Reports (SARs) are an imposed requirement. The Company ensures that any employee reports to the Risk Team where they have grounds for knowledge or suspicion that a person or customer is engaged in money laundering or terrorist financing.

Escalations of SARs should be done in a confidential, discreet manner, in a handwritten form and not via email so as to ensure maximum anonymity.

An employee must not, under any circumstances, disclose or discuss any AML concern with the person or persons subject to an investigation, or any other person for that matter. Disclosure (also known as “tipping off”) is strictly prohibited and carries with it very serious legal penalties.

Furthermore, and in order to keep ourselves protected as much as possible, no remark should ever be left on an account that would give any indication that money laundering is suspected, a player being entitled, at any point in time, to request the full notes/remarks on their account.

5.2 Working Procedure

The Company reviews players spend and game play to check for suspicious activity. Before any withdrawal is processed the following procedures are carried out:

a) The customers deposit history is reviewed to confirm that no suspicious payments have been made to the customer’s account. The frequency of deposits and the sum of deposits are reviewed to ensure they are within normal range for the customer based on his depositing history and the general depositing range throughout our network.

b) The customer’s turnover is reviewed to ensure that they have played in the casino and are not using Company as a method to move money.

c) When possible, funds must always be refunded back to the original payment method used by the player to make a deposit. See Terms & Conditions for more information.

d) Withdrawal Procedure.

When reviewing a customer’s account prior to withdrawal checks:

a) Did the player wager?

b) Does the payment Method belong to the player and has the player used it to deposit?

c) Are the customer’s transactions and bets in line with expectations for the player?

5.3 Withdrawal and Refund Policies

5.3.1 Withdrawals

When withdrawing funds, the Company may to request additional information from the user to confirm the identity of the user and the ownership of his/her account for withdrawal of funds. For example, the Company has the right to request a photo of a user with an open passport against the background of his face (the document should be readable) and photo of the bank card on the front side (5 first and 4 last digits, owner’s name and date of expiry shall be readable) and similar documents and information.

The User must provide the documents and information, requested by the Company, within a period not exceeding 72 hours, otherwise the withdrawal request will not be executed.

If this is the user’s first withdrawal, it may take up to 72 hours for the data to be verified. If the user has previously verified his account and withdrawn funds, subsequent withdrawals will be made without delay within 24 hours, unless circumstances arise as provided by the AML and / or the law and require additional verification of the user’s identity, bank card ownership or risk management by analysis of gaming behavior. In such cases, verification takes 72 hours from the moment, when the user provides all requested documents and information.

Upon receipt of an application for withdrawal of funds, the Company has the right to make available only those payment methods with which the user made a deposit (individually in relation to the user or for a group of users (in relation to currency, country of residence of the user, country or other criteria).

When depositing funds using different (combined) payment methods (using simultaneously different virtual assets and/or currencies), withdrawal of funds is made in one of the virtual assets/currencies, used when depositing funds, at the Company’s sole discretion.

The limits and terms of withdrawal of funds may be extended by the Company until the end of the verification of documents and information, received from the user, in case of suspicion of bonushunting by the user. In this case, the withdrawal term may be extended up to 30 days from the moment, when the user provides the documents and information, requested by the Company. In the same case, the Company has the right to apply restrictions on the use of the account and wagering rules, of which the user will be notified.

5.3.2 Refund

A refund can be requested by the user from the moment funds are credited to the user’s account. To make a refund, the user submits a refund request, which is sent to the Payments Department by email: Payment@Mi7eu.bet, attaching to the request a photo of a user with an open passport against the background of his face (the document should be readable) and photo of the bank card on the front side (5 first and 4 last digits, owner’s name and date of expiry shall be readable) or account details certified by a financial institution with confirmation of the ownership of the account by the user. If the user has not provided all the documents required for the refund within 72 hours from the date of sending the application for a refund, then such an application is not executed.

Verification of data may take up to 72 hours, unless there are circumstances prescribed by the AML and / or law that require additional verification of the user’s identity, bank card ownership or risk management. In such cases, verification takes 72 hours from the moment the user provides the requested documents and information.

At the same time, the Company has the right to additionally request from the user information about the source of funds, the return of which is declared by the user. This information may be in the form of:

  • proof of earnings: Payslip/Director remuneration/Dividends/Pension;
  • a bank statement/savings account that clearly shows consistent incoming values from an identifiable source;
  • a Trust deed clearly showing a consistent entitlement to funds;
  • dated proof of an award/payment made to the user.

The request for a refund is executed upon completion of the verification.

6. EMPLOYEES

6.1 Senior Management

Senior management is fully committed to and responsible for the implementation of this policy. Senior management is made aware of their individual personal liability for consenting to, or conniving in, the commission of offences under the Regulations, or where such offence is attributable to any neglect on his part.

6.2 MLRO

A designated Money Laundering Reporting Officer takes responsibility for SARs in respect of the prevention and detection of money laundering, counter terrorism financing and our obligations.

  • The nominated MLRO has responsibility for:
  • making reports to senior management on anti-money laundering (AML) and countering terrorist financing (CTF) activity;
  • receiving disclosures from employees;
  • and if appropriate, making such external reports.

The MLRO has the authority to act independently in carrying out their responsibilities, and has access to sufficient resources to carry out their duties.

6.3 Staff training

All staff will receive training on their obligations in respect of money laundering reporting and are aware of the procedures in place for escalation of any suspected incidents to the MLRO. As part of this process, staff are made aware that personal disregard for the legal requirements, for example, turning a blind eye to a customer spending criminal proceeds, may result in criminal or regulatory action.

Relevant employees receive training on how to follow house policies and procedures for:

client due diligence (CDD), including enhanced requirements for high risk clients, which includes PEPs;

reporting suspicious activity to the nominated officer where necessary, seeking appropriate consent to allow participation in gaming and to conduct gaming and other business transactions.

7. HIGH RISK JURISDICTIONS

High risk countries are those countries identified as such by publications issued from time to time by the Financial Action Task Force; or additionally those so identified by the Gambling Commission. Client registered in High Risk Countries are always subject to EDD.

Players from the FATF list of jurisdictions seen to threaten the international financial system from on-going and substantial money-laundering or terrorist financing activities, as identified on FATF publications, will be refused.

8. RECORD KEEPING

We ensure that there is an audit trail to assist in any financial investigation by a law enforcement body.

9. OFFENCES

All employees are made aware of their risk of committing the following related offences:

  • failing to report suspicious activity
  • where an employee fails to comply with the obligations to make disclosures to a nominated officer, as soon as practicable after the information giving rise to the knowledge or suspicion comes to that person, they are open to criminal prosecution;
  • they may also commit an offence if they disclose information that an SAR has been submitted that is likely to prejudice any investigation, or disclose information that an investigation into allegations that an offence has been committed, that is likely to prejudice the investigation;
  • they also commit an offence if they know or suspect that an appropriate officer is acting (or proposing to act) in connection with a relevant investigation which is being or is about to be conducted, and they falsify, conceal, destroy or dispose of documents which are relevant to the investigation.

10. VEETING PROCEDURES FOR NEW EMPLOYEES

The company undertakes a number of vetting procedures when staff are employed. We will ensure the employee is not a minor through proper identification checks. We will also look to verify any further personal information or background information.

11. PROTECTING OUR EQUIPMENT FROM

INTERNAL CRIME AND CRIMINAL MISUSE

The company is very aware that a key way to combat fraud is to first identify where the company’s most valuable assets are. Processes and controls have been built into the routine business of the company to minimize the chances of any of the key assets being misused.

Our server equipment are located at Curasao who have in place necessary policies around protection of equipment, for example, a visitors management procedure, fire alarms, shredding of confidential documents, locked cabinets, testing, a security team etc. Company also implements such policies at our offices.

12. ENSURING THE COMPANIES WE DEAL WITH ARE

TRUSTWORTHY AND REPUTABLE

The Company promotes strong principles of business and professional ethics at every level. When selecting suppliers, there are a number of criteria we consider:

  • financial strength (for long term sustainability);
  • legal and regulatory compliance;
  • commitment to a wider corporate responsibility program; and
  • desire and ability to deliver quality and value.

All new suppliers must go through a rigorous approvals process where all information put forward by them is verified.

This information is then assessed internally to consider the risks associated with the supplier; taking into account all of the above criteria. If rejected, the supplier will be informed. The Company ensures that all organisations we contract with understand the compliance obligations under the relevant player jurisdictions.

13. INTERNAL RECORD KEEPING

The below key principles:

know your customer, internal record keeping and reporting, ensure our compliance with laws and regulations.

  • records on all customer transactions - regardless of their relation to payments or plays - will be kept during all the period according the lisence conditions after the transaction;
  • records on customer details - regardless of their value state or open/blocked status - will be kept during all the period according the lisence conditions after the relationship with the customer was terminated;
  • records on money laundering investigations and suspicious activity reports will be kept during all the period according the lisence conditions after the investigation was completed.

II. KYC Policy

(Know Your Customer)

INTRODUCTION

By agreeing to the Terms you authorize us to undertake any verification checks we may require or that may be required by the third parties (including, regulatory bodies) to confirm your identity and contact details (the “Checks”).

During this Checks we may restrict you from withdrawing funds from Your Account.

If any information that you have provided is untrue, inaccurate, misleading, does not match your ID or otherwise incomplete we reserve the right to terminate your account immediately and/or prevent you from using the services, in addition to any other action that we may choose to take.

If a fact that you were under the Legal age at the time you made any gambling or gaming transactions, then:

  • your Account will be closed;
  • all transactions made during that time will become void, and all related funds deposited by you will be returned in amount;
  • any winnings which you have accrued during that time will be forfeited from you and you will be required to return to us all funds that were withdrawn from Your Account. In the event of any change in your personal details You are required to inform us by contacting Support.

In case of any changes in your personal data, you must inform us about this by contacting the support service.

1. OBJECTIVE OF THE POLICY

The Company shall request verification of the user of its Services at the following situations:

  • Suspicion of fraud, money-laundering, criminal activity etc.;
  • Doubts about the authenticity of the provided documents;
  • Violation of conditions for using the services of the Company;
  • Any other situation the Company shall deem appropriate.
  • By means of that request the Company may demand a standard set of identification data and documents, as well as additional documents.
  • The minimum set of identification data includes:
  • full name;
  • date of birth;
  • citizenship;
  • address of permanent residence;
  • an identification number.
  • The required documents are:
  • actual passport of the client / ID card;
  • document confirming the address of the client’s permanent residence at the given time (utility bill, statement of the status of the bank account, etc.)

Additional documents are:

  • additional national identity card (driver’s license, military ID, etc.);
  • photos of a user with an open passport against the background of his face (the document should be readable)
  • photo of the bank card on the front side (5 first and 4 last digits, owner’s name and date of expiry shall be readable).
  • Also the Company may ask the User to provide source of funds documentation which is important to make sure that user provides evidence that identifies the actual source(s) of funds that he uses to bet or play with.

This information may be in the form of:

  • proof of earnings: Payslip/Director remuneration/Dividends/Pension;
  • a bank statement/savings account that clearly shows consistent incoming values from an identifiable source;
  • a Trust deed clearly showing a consistent entitlement to funds;
  • dated proof of an award/payment made to the user.
  • The User must provide documents and information at the request of the company within 72 hours of receiving the request from the Company. The verification of the documents and information provided by the User takes 72 hours from the moment the User submits the requested documents and information, unless there are circumstances required by AML requirements and/or the law, which require additional verification of the User’s identity, bank cards belonging or risk management.

The documents that the user provided shall be not approved because:

  • address/Name on documents don’t match with account name/address;
  • illegible documents or copies;
  • document Not Acceptable (for example user sends a copy of a document that is not on the accepted documents for ID verification or a copy of mail envelope instead of an actual utility bill);
  • any other reasons employees or contractors of the Company shall deem appropriate.
  • Upon the results of the analysis of the documents provided, the Company shall make a solution according to the Terms and Conditions, Privacy policy, License agreement of the Website and legislation requirements.

Mi7eu.bet has the absolute right to make an additional verification of the client by means of a telephone call to the number, specified by the client in the registration of the account, as well as video verification of the client’s identity.

2. OBLIGATIONS

Due diligence (DD): Company’s customers should be subject to a DD process and record keeping.

Duplicate/Multiple Accounts: Many customers wish to operate parallel accounts in order to segregate their gambling spend. Notwithstanding this activity, Company shall identify and associate linked’ accounts that may belong or be under the control of the same person. Company shall be entitled to cancel additional accounts or accounts of the player in question, cancel winnings thus gained and return deposits to the owner of the account.

Politically Exposed Persons (PEP): Company have to respond to any attempt to gamble by any person qualifying as Politically Exposed Person, i.e. any person holding significant public office (or who has held it at any time in the preceding year), having access to public funds or in a position of influence. PEPs include the readily identifiable family and associates of such persons. A risk based approach should be applied based on the value and scale of gambling and the location of such customer.

The Company reserves the exclusive right to unilaterally decline any clients’ application and/or terminate further provision of services without any statements or explanations to the client in case of breach of KYC procedure.

Version 1.3. dated 10.04.2024