Anti-Money Laundering (AML) Policy

Anti-Money Laundering (AML) Policy

1. Introduction

1.1 Money Laundering

Money Laundering (ML) is the process of concealing the origins of illegally obtained money, typically by passing it through a complex sequence of banking transfers or commercial transactions. Criminals attempt to make their illicit gains appear legitimate, often involving activities such as drug trafficking or terrorist financing.

1.2 Anti-Money Laundering

Anti-Money Laundering (AML) refers to the laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. An effective AML program requires financial institutions and other regulated entities to implement measures to prevent, detect, and report ML activities.

2. Regulation

Employees in the gaming industry are mandated to report any information that suggests a person may be engaged in money laundering or terrorist financing. This includes:

  • Knowledge of suspicious activities
  • Reasonable grounds for suspicion

These obligations ensure that businesses can demonstrate adequate risk assessments and customer due diligence.

3. Crime & Disorder and AML Policy

Our AML policy is based on several principles:

  • Development of systems and controls that comply with legal and regulatory requirements.
  • Annual assessment of AML risks inherent in our business.
  • Commitment from senior management to uphold these standards.
  • Regular assessments of the adequacy of our systems and controls.
  • Maintenance of records that meet law enforcement needs.

4. Risk Management

We adopt a risk-based approach to manage and mitigate money laundering risks by:

  • Identifying relevant risks
  • Designing policies to mitigate those risks
  • Monitoring the effectiveness of these controls
  • Keeping records of actions taken

5. Suspicious Activity

Suspicious activity includes unusual transactions or extreme player profiles. Examples include:

1. Passport or ID verification
2. Utility bills
3. Bank statements
4. Other identity proofs

Enhanced due diligence checks are conducted based on risk profiles.

5.1 Suspicious Activity Reports (SARs)

Employees must report any grounds for suspicion regarding money laundering activities to the Risk Team confidentially. Disclosure of an ongoing investigation is strictly prohibited.

5.2 Working Procedure

Before processing withdrawals, we review customer deposit history and turnover to ensure no suspicious payments have been made.

5.3 Withdrawal Procedure

Prior to withdrawal, agents must verify:

1. Did the player wager?
2. Does the payment method belong to the player?
3. Are transactions in line with expectations?

6. Employees

6.1 Senior Management

Senior management is responsible for implementing this policy and is aware of their liability under AML regulations.

6.2 Money Laundering Reporting Officer (MLRO)

The MLRO oversees SARs related to money laundering and has the authority to act independently.

6.3 Staff Training

All staff receive training on their responsibilities regarding money laundering reporting.

7. High-Risk Jurisdictions

Countries identified as high-risk by the Financial Action Task Force (FATF) require enhanced due diligence for clients registered in those jurisdictions.

8. Record Keeping

We maintain comprehensive records for compliance purposes, including transaction details, employee training records, and SARs.

9. Offences

Employees are informed about the legal implications of failing to report suspicious activities, which can lead to criminal prosecution.

10. Vetting Procedures for New Employees

We conduct thorough vetting processes for new hires, including identification checks and reference verification.

11. Protecting Our Equipment from Internal Crime

We implement strict controls to protect our assets from misuse or fraud.

12. Compliance and Risk Committee

A committee will review executive risk quarterly, including members from senior management.

13. Ensuring Trustworthy Partnerships

We assess potential suppliers based on financial strength, legal compliance, and commitment to corporate responsibility.

14. Responsibilities Under POCA

We adhere strictly to the Proceeds of Crime Act (POCA) regulations in our operations.

15. Internal Record Keeping

Records are maintained for at least six years post-transaction or after an investigation concludes.

16. Prevention of Collusion and Data Protection Compliance

Cheating will not be tolerated; customer data is securely stored and managed according to strict policies.

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