Anti-Money Laundering (AML) Program and Compliance Procedures
- GammonSpace Ltd, with its registered office at Ewropa Business Centre, Level 3 – 701, Durn Karm Street, Birkirkara, BKR 9034, Malta, which is registered in the Registrar of Companies, Reg. No. C 91360 (the “Company”), sets up the AML Program and Compliance procedures to prohibit and actively prevent money laundering and any activity that facilitates money laundering or funding of terrorist or criminal activities (the “Company Policy”). The Company strives to comply with all applicable requirements under the legislations in force in the jurisdictions in which the Company operates, to prevent the use of the financial system for the purpose of money laundering and terrorist financing.
- The Company is a limited liability company duly incorporated and existing under the laws of Malta.
Objective of the Policy
- The Company is fully committed to be constantly vigilant to prevent money laundering and combat terrorism financing in order to minimize and manage risks such as the reputational risk, legal risk and regulatory risk. It is also committed to prevent serious crimes and not to allow its systems to be abused in furtherance of these crimes.
- The Company will endeavor to keep itself updated with developments on any initiatives to prevent money laundering and terrorism financing both at national and international level. It commits itself to protect, at all times, the organization and its operations and safeguards its reputation from the threat of money laundering, the funding of terrorist and other criminal activities.
- The Company's policies, procedures and internal controls are designed to ensure compliance with all applicable laws, rules, directives and regulations relevant to the Company's operations and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place.
Player Identification Program
- The Company will take reasonable steps to establish the identification of any person for whom it is proposed to provide its service (the “Players”). For this purpose, the registration process of Players requires provision of information defined herein.
- The Company will keep at all times a secure online list of all registered Players and any information and documents pertaining to them will be retained in accordance with the applicable data protection regulations.
- The Company shall not open any anonymous accounts or accounts in fictitious names and other data.
- During the registration process, the Player is obliged to provide i) his/her country of residence, ii) his/her nickname, iii) his/her email and iv) his/her telephone number.
- Before deposition of money or payment of money to the Player’s account, the Player is obliged to provide additionally i) his/her name and surname, ii) his/her date of birth verified by ID document, iii) his/her address verified by a utility bill, and iv) bank information verified by a statement or letter issued by the bank.
- The Company may independently verify the Player's identity through i) the comparison of information provided by the Player with information obtained from a reporting agency, public database or other source, ii) checking references with financial institutions, or iii) obtaining a Player's financial statement.
- The Company shall inform the Player that it may seek further identification information to verify his/her identity.
- Any employee of the Company who becomes aware of an uncertainty in relation to the accuracy and truthfulness of the Player information provided shall immediately notify the AML Compliance Officer, who will review the materials and determine whether further identification is required and if so that it may be determined whether a report is to be sent to the relevant authorities.
- If a potential or existing Player either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the Company will not open a new account and, after considering the risks involved, it may close any existing account. In either case, the AML Compliance Officer will be notified so that it may be determined whether a report is to be sent to the relevant authorities.
- If a Player has been identified as attempting or participating in any criminal or unlawful activity, the Company will take the appropriate steps to immediately freeze the Player's account.
- The Player is obliged to inform the Company if any of the information set out in the 3.4 and 3.5 has changed.
Continuous transaction due diligence
- The Company will monitor Player's account activity with special attention, and to the extent possible, the background and purpose of any more complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.
- Monitoring shall be conducted through the following methods: Transactions shall be automatically monitored and reviewed daily for all transactions along with all the details of the Players making those transactions. Documents may be required at the determination of the AML Compliance Officer.
- The AML Compliance Officer shall be responsible for this monitoring; shall review any activity that the monitoring system detects; shall determine whether any additional steps are required; shall document when and how this monitoring is carried out; and shall report suspicious activities to the relevant authorities.
- The Players are limited to deposit money to their accounts as follows:
- Player is allowed to deposit max. EUR 600 to his/her account per 24 hours;
- Player is allowed to deposit max. EUR 2000 to his/her account per 1 week;
- Player is allowed to deposit max. EUR 5000 to his/her account per 1 month;
- No transfers between Players’ accounts are allowed. In case the Company detects such a transfer, the affected Players’ accounts shall be frozen immediately and further inspected.
- Parameters indicating potential money laundering or terrorist financing include, but are not limited to:
- Wire transfers to/from financial secrecy havens or a high-risk geographical location without any apparent reason;
- Large number of small, incoming wire transfers or deposits made using checks and money orders;
- Wire activity that is unexplained, repetitive, unusually large or shows unusual patterns or with no apparent specific purpose.
- In case the Company detects any signs of collusion at the Player’s account, it shall screen the affected account via its transaction monitoring system and freeze the respective Player’s account until resolved. In case of collusion, all involved accounts can be closed.
- When an employee of the Company detects any activity that may be suspicious, he or she shall notify the AML Compliance Officer. AML Compliance Officer 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 or closing the account and/or filing a report.
- The Company will not accept cash or non-electronic payments from Players. Funds may be received from Players only by any of the following methods:
- credit cards;
- debit cards; and
- other method only if approved by the Company and applicable legal regulations.
- The Company will only transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.
- To the extent the Company utilizes a third party as a service provider to process and record payments to and from Player and accounts, the Company shall use best efforts to ensure the service provider has transaction monitoring systems in place which will allow for screening of the transactions pursuant to these provisions and in accordance with the applicable legislation. The AML Compliance Officer shall be responsible to review the relevant service agreement with the service provider to ensure the adequacy of the agreement.
- Records relating to the financial transactions shall be maintained in accordance with the data protection and retention requirements in the applicable jurisdiction of Malta.
Suspicious Transactions and Reporting
- The AML Compliance Officer will report any suspicious transactions (including deposits and transfers) conducted or attempted by, at or through a Player’s account in case the AML Compliance Officer knows, suspects or has reason to suspect that:
- the Player is included on any list of individuals associated with terrorism or on any sanctions list;
- the transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade relevant laws or regulations or to avoid any transaction reporting requirement under relevant laws or regulations;
- the transaction has no ordinary lawful purpose or is not of the kind in which the Player would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or
- the transaction involves the use of the Company to facilitate criminal activity.
- The Company will hold regular employee training under the leadership of the AML Compliance Officer and senior management. The training shall occur on at least an annual basis. The training shall be updated as necessary to reflect any amendments to the relevant legal regulations.
- The training will include, at a minimum:
- how to identify red flags and signs of money laundering that arise during the course of the employees' duties;
- what to do once the risk is identified (including how, when and to whom to escalate unusual Player activity or other red flags for analysis);
- what are the employees' roles are in the Company's compliance efforts and how to perform them;
- the Company's records retention policy;
- the disciplinary consequences for non-compliance with the applicable legislation.