Anti Money Laundering Policy for Pin Up Online Casino in Bangladesh

Foreword

1.1 Concealing Illegal Profits

Money laundering is the process of concealing assets obtained through illegal activities, like drug trafficking or terrorism, to make them look like they come from legitimate sources. Criminals aim to hide the origins, change the format, or move the assets to places where they face less examination.

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1.2 Approaches to Combat Money Laundering

Anti-money laundering (AML) encompasses a set of legal requirements that compel financial institutions and other regulated entities to prevent, identify, and report occurrences of money laundering. A successful AML strategy requires:

  • Prohibition of money laundering activities by law
  • Equipping regulatory and law enforcement agencies with the necessary investigative tools.
  • Financial institutions must identify customers, implement risk-based controls, maintain records, and report any suspicious activities.
  • Enabling the exchange of information across borders as necessary

Governance and Regulation

When employees in the digital gaming sector come across any information related to possible money laundering or funding of terrorism during their work, they are required to report it.

  • They are certain
  • They suspect

There are valid reasons for them to suspect that illicit activities may be occurring. The criteria outlined together establish the foundation for the necessary reporting. Regulators look for proof of risk assessments that were carried out before starting business relationships, as well as sufficient customer due diligence to confirm that transactions correspond with the identified risk profiles.

Merchants are required to show that their monitoring efforts are sensitive to risks and to keep precise records that reflect this, adjusting risk profiles as needed. This documentation should detail extra measures taken for risk monitoring and situations that require a declaration of the sources of funds from customers in high-risk cases.

2.1 Particular Legal Obligations

The Merchant pledges to embed compliance deeply within every aspect of the business, supported by the licensed Curacao Gaming License that allows for online games of chance.

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Regulations, Chaos, and Anti-Money Laundering Strategies

The principles and protocols of AML consist of:

  • Creating appropriate systems and controls that adhere to legal requirements
  • Every year, evaluating the AML risks related to the business and implementing a proactive, risk-oriented strategy.
  • Regularly conducting evaluations of the system and control.
  • Providing our assigned officer with the necessary resources and independence

Risk Handling

As outlined by the Money Laundering Regulations 2007, our method of managing risk includes:

  • Recognizing the particular risks of money laundering and terrorist financing that are relevant to us
  • Creating and implementing strategies to reduce these risks
  • Regularly assessing and improving the efficiency of these policies
  • Recording the steps taken along with the reasons for those actions.

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Suspicious Activities

This involves recognizing unusual transactions and extreme player profiles, among other signs. Heightened due diligence is necessary based on:

  • Verification of passport or ID
  • Utility bill
  • Bank statements
  • Further evidence of identity

A more detailed examination is required depending on the risk profiles of players and other established criteria, leading to in-depth investigations of customers' backgrounds and assets.

Procedures for Reporting and Escalation

Suspicious Activity Reports (SARs) are mandatory, and escalations are handled discreetly to maintain confidentiality. Employees must refrain from discussing AML issues with those being investigated or anyone else, as such disclosures could lead to legal repercussions.

Training and Management of Employees

The implementation of AML policies is championed by senior management, while the designated Money Laundering Reporting Officer (MLRO) is responsible for ensuring compliance. Training for employees promotes awareness of their AML responsibilities and helps maintain adherence to established protocols.

High Risk Jurisdictions

Countries that are recognized as high-risk by the Financial Action Task Force or by gambling regulators face rigorous due diligence, particularly when linked to significant risks of money laundering or terrorist financing.

Oversight of Compliance and Maintenance of Records

Detailed records that back compliance and investigative activities are kept, along with thorough documentation of employee training and internal reporting.

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Conclusion

The Merchant stays alert against illegal activities by following these strict guidelines, which help ensure compliance and protect against the misuse of our systems for unlawful purposes.