Pin Up Bet Anti Money Laundering Policy (AML) in Bangladesh
1. Preface
1.1 What is Money Laundering?
Money Laundering (ML) is the artifice of transforming assets stemming from illicit activities, such as drug distribution or terrorism, into something that appears squeaky-clean. Those who launder money aim to mask the origin and manipulate the appearance of funds, making them seem like they stem from a bona fide source. They accomplish this by obscuring the origins, converting them into different forms, or transferring them to a location less likely to raise eyebrows.
1.2 Understanding Anti-Money Laundering
The term Anti-Money Laundering (AML) refers to a financial/legal framework devised to mandate financial institutions and other regulated bodies to thwart, recognize, and report ML incidents. An effective AML strategy mandates that a jurisdiction should:
- Enact legislation that criminalizes Money Laundering.
- Equip regulatory bodies and law enforcement with the authority and tools to scrutinize these activities.
- Require financial institutions to verify their clientele, enforce risk-based protocols, maintain records, and report any dubious transactions.
- Facilitate the exchange of information between jurisdictions as deemed necessary.
2. Regulatory Framework
Employees in the remote gaming industry are obligated to report any information encountered during business operations if they:
- Are aware
- Suspect
Have reasonable grounds to believe that an individual is involved in money laundering or terrorist financing, including spending derived from criminal activities.
These prerequisites are collectively termed as grounds for knowledge or suspicion. Authorities anticipate that we can substantiate, with corroborative proof, that a comprehensive risk assessment is carried out before engaging in business with clients and that adequate customer due diligence is implemented to ascertain that the transactions align with the assessed risk.
The Merchant must demonstrate that ongoing monitoring is based on a risk-oriented approach, and all records are meticulously kept to reflect this, with risk profiles being adequately maintained. This document outlines additional measures implemented to monitor risks, including situations where we would necessitate a Declaration of Funds Source from clients when the risk of money laundering is elevated.
2.1 Specific Regulations
The Merchant is dedicated to embedding compliance into every aspect of our operations, adhering to a licensed Curacao Gaming License that allows for Games of Chance in the International market.
3. Crime & Disorder and AML Strategy
The AML strategy is built on fundamental tenets and practices:
- We design systems and controls that are apt for our business and comply with legal and regulatory mandates.
- We evaluate the inherent AML risks in our operations at least once a year, adopting a risk-based approach that is nimble, efficacious, and cost-efficient.
- The responsibility for this falls squarely on senior management.
- We periodically assess the efficacy of our systems and controls.
- We retain records of transactions to support any law enforcement inquiry related to money laundering and terrorist financing.
- We offer both initial and continuous training to all relevant personnel.
- We provide resources and autonomy to the nominated officer for objective and independent operation.
4. Managing Risks
We have policies and protocols for risk assessment and management, as required under the Money Laundering Regulations 2007. This risk-based strategy entails several key steps in determining the most suitable way to manage and mitigate the money laundering and terrorist financing risks we face:
- Recognize the pertinent risks.
- Craft and implement policies to mitigate those risks.
- Monitor and refine the controls’ effectiveness.
- Document the actions taken, and why.
This risk-oriented approach directs efforts where they are most required and likely to yield the greatest impact. It has the full backing and support of our senior management and the collaboration of all staff. We have undertaken an analysis of our business’s exposure to money laundering, considering the threat and its ramifications.
5. Identifying Suspicious Activity
Suspicious Activity encompasses suspicious transactions, extreme player profiles, or inconsistent deposits. Concrete examples of suspicious player behavior that necessitate a risk monitoring approach and enhanced due diligence checks include:
- A passport or ID card.
- A utility bill.
- A bank statement.
- Other proof of identity.
Enhanced Due Diligence Checks are subject to the player’s profile and the risk they pose to us. Should we determine that one or more of the above criteria are met, we flag the customer for further investigation, including checking their place of employment, the value of their residence, and if their spending is logical given these factors.
5.1 Suspicious Activity Reports (SARs)
Under this framework, Suspicious Activity Reports (SARs) are a mandatory requirement. The Merchant ensures that any employee reports to the Risk Team if they suspect or know of any ML or terrorist financing activities. Employees failing to do so may face criminal charges.
The escalation of SARs must be done discreetly, preferably handwritten, to ensure anonymity. Employees must not disclose or discuss any AML concerns with the person under investigation or anyone else, as this is strictly prohibited and carries severe legal repercussions.
5.2 Operations Protocol
The Merchant scrutinizes player spending and gameplay to detect suspicious activity. Before processing any withdrawals, the following procedures are undertaken:
- Reviewing the customer’s deposit history to confirm no suspicious payments have been made to their account.
- Ensuring the customer has played in the casino and isn’t using the Merchant as a conduit for moving money.
- Refunding funds back to the original payment method whenever possible.
5.3 Withdrawal Procedure
When reviewing a customer’s account before withdrawal, the agent must address the following in the AML segment in the Risk Entry:
- Has the player wagered?
- Does the payment method belong to the player, and has the player used it to deposit?
- Are the customer’s transactions and bets in line with the expected patterns?
5.4 Escalation Process
Following the established AML policies and escalating any suspicious activity is crucial to protect the company from financial losses and ensure compliance with various jurisdictions’ regulations.
Any activity that appears suspicious, even slightly, must be escalated. Failure to do so could lead to criminal prosecution.
6. Employees
6.1 Senior Management
Senior management bears full responsibility for implementing this policy. They are also aware of their liability for offenses under the Regulations or any neglect that contributes to an offense.
6.2 MLRO
A designated Money Laundering Reporting Officer (Nikos Lazos; [email protected]; +35780077001) is responsible for SARs related to anti-money laundering, counter-terrorism financing, and compliance with the Proceeds of Crime Act 2000. The MLRO has the autonomy to act independently and access to the resources needed to perform their duties.
6.3 Staff Training
All staff receive training on their obligations regarding money laundering reporting and are informed of the procedures for escalating any suspected incidents to the MLRO. They understand that disregarding legal requirements could result in regulatory or criminal action.
Relevant employees are trained to follow internal policies for:
- Client due diligence, including enhanced requirements for high-risk clients and Politically Exposed Persons (PEPs).
- Reporting suspicious activity to the nominated officer, seeking appropriate consent for gaming participation and other business transactions.
7. High-Risk Jurisdictions
High-risk jurisdictions are those identified by the Financial Action Task Force or the Gambling Commission. Clients registered in High-Risk Countries are subject to Enhanced Due Diligence.
Countries on the FATF list, such as Afghanistan, Algeria, Angola, and others, are avoided. Players from these jurisdictions are not permitted due to their potential connection with ongoing and substantial money-laundering or terrorist financing activities.
8. Record Keeping
We ensure there’s an audit trail to assist with any law enforcement inquiries into financial investigations. Our record-keeping policy encompasses records related to:
- How compliance is monitored by the nominated officer.
- Customer identification and verification information.
- Employee training records.
- Internal and external SARs.
Contact between the nominated officer and law enforcement or the National Crime Agency, among other records.
9. Offenses
All employees are made aware of their risk of committing related offenses:
- Offenses under the Proceeds of Crime Act (POCA) and Terrorism Act for failing to report suspicious activity.
- Disclosing information that could prejudice investigations (“tipping off”).
- Falsifying, concealing, or destroying documents relevant to an investigation.
10. Vetting Procedures for New Employees
Pin Up Bet has stringent vetting processes for new employees, including proper identification checks, independent references, and verification of personal information and background.
11. Safeguarding Equipment from Internal Crime and Misuse
We have measures to prevent internal crime and misuse of equipment, including a visitor management system, fire alarms, shredding confidential documents, locked cabinets, and a security team at our server locations.
12. Compliance and Risk Committee
We plan to establish a Compliance and Risk Committee to oversee executive risk, consisting of the MLRO, Compliance Officer, and another non-executive director. They will meet at least quarterly or as needed.
13. Ensuring Business Integrity with Partner Companies
The Merchant promotes strong business ethics at every level. When selecting suppliers, we consider criteria such as:
- Financial stability for long-term sustainability.
- Legal and regulatory compliance.
- Commitment to corporate responsibility.
- Capability to deliver quality and value.
All new suppliers undergo rigorous approvals to ensure they meet these standards.
14. Responsibilities under the Proceeds of Crime Act (POCA)
Merchant is fully aware of the procedures and policies required by the Proceeds of Crime Act 2002, adhering to strict compliance measures.
15. Internal Record Keeping
Our key principles for internal record keeping ensure compliance with laws and regulations. We retain records of all customer transactions for at least six years, regardless of their relation to payments or plays. Records of customer details and money laundering investigations are also kept for six years, even after the customer’s relationship with us has ended.
16. Preventing Collusion and Complying with Data Protection
Our Terms and Conditions strictly prohibit cheating, and accounts suspected of cheating will be closed. Data protection policies ensure that all sensitive customer information is stored securely, encrypted, and managed by a third-party company. All employees adhere to strict information security policies, including System Access Control, Password Policies, Malware Protection, and Network Control.