Policy approval
The company is further approved to accept and transact with customers in either fiat (traditional currencies), crypto (digital or virtual) currencies or a combination of both.
We are committed to preventing our systems from being used for Money Laundering, Terrorist Financing or other crime. This includes actioning the following steps:
General provisions
We are fully committed to applying measures to prevent Money Laundering and Combatting Terrorism Financing. We are also committed to our social duty in preventing our systems from being used as a tool for crime.
We will endeavour to stay updated with developments in prevention measures in order to protect the organisation, its operations and reputation.
Our policies and procedures were built and continue to be updated to observe the laws relevant to our operations.
Laws and regulations
The Curaçao Gaming Control Board is the designated supervisory Authority for our service.
We are required to comply with all applicable laws and regulations within the jurisdiction of Curaçao, including National Ordinances covering the criminal code, identification for services, identification when rendering services, and the reporting of unusual transactions.
We are required as a service provider of online games of chance to have in place adequate practices and procedures to prevent our systems from activity facilitating money laundering and the funding of terrorist and criminal activities.
Customer due diligence
We will apply appropriate customer due diligence measures required by law, including utilising identifiers.
We will apply due diligence checks as part of its customer registration procedures, verifying age, name, residential address, nationality, PEP and a sanctions check.
At any time a customer’s risk profile changes based upon any number of ‘red flags’, we will conduct enhanced due diligence, including verification based on personal documents, and publicly held data, privilege information from other operators and sources, financial or corporate data, and third-party data providers.
We have a duty to monitor all customer relationships in accordance with industry best practice, international recommendations and guidelines.
Any suspicious transactions or circumstances potentially related to Money Laundering and Terrorist Financing will be reported to the relevant law enforcement authority.
Where due diligence checks cannot be completed, we will suspend the business relationship until such time as all checks have been satisfactorily completed.
Cryptocurrency transactions
The company is entitled to perform additional background and security checks for the customers wishing to deposit or withdraw using cryptocurrencies. In case of suspicion, the company has the right to suspend the customer account and request additional Due Diligence documentation from the customer.
If we are not able to be assured of either the identity of the customer or the source of funding, the matter can be referred to the management board and service provider for review and final decision.
If the decision is to terminate the relationship any retained customer funds will be held in a seized funds account and declared as part of any suspicious activity report made to law enforcement.
Reporting suspicions
As a Curacao eGaming IP licensee, we are obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance and as a registered body of the Department of the Financial Intelligence Unit (FIU).
A customer being identified as being on a sanctions list, linked to Money Laundering, the Financing of Terrorism, or other criminal activity, may warrant the submission of a formal suspicious activity report to law enforcement.