AML policy

Gaming environment is generally often targeted by those who wish to launder money. The speed of the transactions and the usage of multiple payment processing options make gaming businesses especially vulnerable to this activity. As a result, many of the initial trading and procedural decisions are either directly aimed at combating this threat or protections are enhanced as a by-product of the overall commercial and trading strategy taken by the business. All staff will be given training in Money Laundering indicators, such as (but not limited to): 1. Unusual betting patterns; 2. Suspicious deposit and withdrawal patterns (size and frequency); 3. Reliability of card data; 4. Customer verification issues and identity theft; 5. Account linkage/multiple accounting. Systems will be operating to record all transactions for an account. These account histories will be subject to a program of regular and continual checks against fraud and social responsibility indicators. Where unusual bet patterns and winning patterns are detected, these will also be cross-references to call history to ensure that staff are not colluding with customers or acting illicitly. The company will also keep a register of those customers that it identifies as high-risk. Those accounts will be subject to greater scrutiny and frequency of checks. Company will take all necessary measure to ensure the propriety of its relationships with other businesses. This will entail a standardized due diligence approach often accompanied by Non-Disclosure Agreements where appropriate. This will require default disclosure of ownership and management structures, company incorporation details, address and contact details