Anti Money Laundering

Action Plan - System for the Prevention of Money Laundering and Financing of Terrorism

  1. It is the policy of 724bet (the "Company") to actively prohibit and prevent money laundering and any activity that facilitates money laundering or the financing of terrorist or criminal activities. The Company strives to comply with all applicable requirements under the laws in force in the jurisdictions in which it operates, to prevent the use of the financial system for money laundering and terrorist financing purposes. The Company is authorized to operate and is regulated by the Ministry of Finance and Public Credit of the Republic of Nicaragua, to offer remote games over the Internet, LAW N°. 766 "SPECIAL LAW FOR THE CONTROL AND REGULATION OF CASINOS AND GAMING HALLS", approved on May 25, 2011, Published in La Gaceta, Official Gazette No. 124 of July 5, 2011. Under the conditions of the license issued by MHCP, the Company must have adequate measures in place to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity.

 

Objective of the policy

  1. The Company is firmly committed to being constantly vigilant to prevent money laundering and combat terrorist financing in order to minimize and manage risks such as reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not allow its systems to be abused to promote these crimes.
  2. The Company will endeavor to keep up to date with developments both domestically and internationally on any initiative to prevent money laundering and terrorist financing. It is committed to protecting, at all times, the organization and its operations and safeguarding its reputation and everything from the threat of money laundering, terrorist financing and other criminal activities.
  3. The Company's policies, procedures and internal controls are designed to ensure compliance with all laws, rules, directives and regulations relevant to the Company's operations and will be reviewed and updated periodically to ensure that appropriate policies, procedures and internal controls are implemented.

 

Player ID Program

  1. The Company will take reasonable steps to establish the identity of any person to whom it intends to provide its service (hereinafter referred to as "Players"). For this purpose, the Player registration process provided for in the Company's General Terms and Conditions provides for the due diligence process that must be carried out before opening a user account.
  2. The Company will at all times maintain a secure online list of all registered Players and the information and documents will be kept in accordance with applicable data protection obligations.
  3. The Company will collect certain minimum Player identification information from each Player who opens an account. The Company will not agree to open anonymous accounts or accounts with fictitious names so that the true beneficiary is not known. The information required shall include at least:

 

  • Player's date of birth (proving that the player is over eighteen (18) years old);
  • Name and surname of the player;
  • place of residence of the player;
  • Valid player email address; and
  • Player username and password.
    • The Player will be asked for documents to verify the identity information received if and when risk or uncertainty is deemed to exist about the information provided and prior to any payment exceeding $1,000 per occasion or when payments to the account are made in excess. of $1,000. These documents shall include, to the extent permitted by applicable data protection regulations:
  • A copy of a valid identity card or passport;
  • Proof of address.
    • The Company may supplement the use of documentary evidence using other means, which may include:
  • Independently verify the identity of the Player by comparing the information provided by the Player with information obtained from a reporting agency, public database or other source;
  • Reference checking with financial institutions; or
  • Obtaining a financial statement.
    • The Company will inform the relevant Players that the Company may seek identifying information to verify their identity.
    • Any employee of the Company who becomes aware of an uncertainty regarding the accuracy and veracity of the Player information provided shall immediately notify the SPLD/FT Risk and Compliance Officer, who will review the materials and determine whether additional identification is required or whether a report should be submitted to the relevant authorities can be determined.
    • If a potential or existing Player 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, will consider closing any existing accounts. In either case, the SPLD/FT Risk and Compliance Officer will be notified to determine whether a report should be sent to the appropriate authorities.
    • If a Player is identified as attempting or engaging in any criminal or illegal activity, the Company will take appropriate steps to immediately freeze the Player's account.
    • If any material personal information of a player changes, verification documents will be requested.

Ongoing transactional due diligence

  1. The Company will monitor account activity with particular attention, and to the extent possible, the background and purpose of any more complex or large transaction and any transaction that is particularly likely, by its nature, to be related to money laundering or terrorist financing.
  2. Monitoring will be carried out through the following methods: Transactions will be automatically monitored and reviewed daily for all transactions over 1000 USD along with all details of the users making those transactions. Documents may be required to be determined by the SPLD/FT Risk and Compliance Officer.
  3. The SPLD/FT Risk and Compliance Officer will be responsible for this monitoring, review any activity detected by the monitoring system, determine if additional steps are required, document when and how this monitoring takes place, and report suspicious activity to the relevant authorities.
  4. Parameters that signal possible money laundering or terrorist financing include, but are not limited to:
  • Wire transfers to/from havens of financial secrecy or high-risk geographic location for no apparent reason.
  • Many small incoming wire transfers or deposits made with checks and money orders.
  • Wiring activity that is unexplained, repetitive, unusually large, or shows unusual patterns or no apparent specific purpose.
    • When an employee of the Company detects any activity that may be suspicious, it will notify the SPLD/FT Risk and Compliance Officer. The SPLD/CFT Risk and Compliance Officer will determine whether and how to investigate the matter further. This may include collecting additional information internally or from third-party sources, contacting the government, freezing the account, and/or filing a report.
    • The Company will not accept cash or non-electronic payments from Players, with the exception of in-person players in game rooms with a maximum amount of 1000 USD. Funds may be received from Players using any of the following methods: credit cards, debit cards, wire transfer, wire transfer checks and any other method approved by the Company or the respective regulators.
    • The Company will only transfer profit payments or refunds to the same route from which the funds originated, where possible.
    • To the extent that the Company uses a third party to process and record payments to and from the Player and accounts, the Company will make every effort to ensure that the service provider has transaction monitoring systems in place that allow verification of transactions in accordance with these provisions. and in accordance with applicable law. The SPLD/CFT Risk and Compliance Officer will be responsible for reviewing the relevant service agreement with the service provider to ensure the adequacy of the agreement.
    • Records related to financial transactions will be maintained in accordance with data protection and retention requirements in the relevant jurisdiction of Nicaragua.

 

Suspicious Transactions and Reports

The SPLD/FT Risk and Compliance Officer will report any suspicious transactions (including deposits and transfers) made or attempted by, in or through a Player Account involving USD 1,000 or more of funds (either individually or in aggregate) where the SPLD/FT Risk and Compliance Officer knows, suspects or has reason to suspect:

    1. The Player is included in any list of persons allegedly associated with terrorism or in a sanctions list;
    2. The transaction involves funds derived from illegal activities or is intended or carried out for the purpose of concealing or disguising funds or assets derived from illegal activities as part of a scheme to violate or evade laws or regulations or to circumvent any transaction reporting requirements under law or regulation;
    3. The transaction has no ordinary legal purpose or is not of the type in which the Player is normally expected to participate, and after examining the background, possible purpose of the transaction and other facts, the Company does not know a reasonable explanation for the transaction; or
    4. The transaction involves the use of the Company to facilitate criminal activity.

Appointment and Role of the SPLD/FT Compliance Officer

  1. The SPLD/FT Risk and Compliance Officer must be an employee of the Company. The General Manager may appoint an SPLD/FT Risk and Compliance Officer to report directly to the General Manager.
  2. The following are the functions of the SPLD/CFT Risk and Compliance Officer:
  • Implement and enforce SPLD/CFT policies across the enterprise;
  • Have at all times full and timely access to customer identification data, transaction logs and other relevant information;
  • Coordinate and monitor day-to-day compliance with applicable SPLD/CFT laws and regulations, as well as their policies, practices, procedures and internal controls;
  • Be the central point of contact for communicating with regulatory and/or investigative agencies;
  • Oversee, review and coordinate the applications and compliance with SPLD/CFT policies of financial institutions. This will include an SPLD/FT risk assessment, account opening practices, procedures and controls, KYC procedures and continuous account/transaction monitoring to detect suspicious transactions/account activities.
  • Ensure that the financial institution has an SPLD/CFT policy as well as a provision for the annual review of the SPLD/CFT policy. The SPLD/FT policy must be approved by the general manager.

 

Training programs

  1. The Company will develop ongoing employee training under the leadership of the AML Compliance Person and senior management. The training will be held at least once a year. It will be based on the size of the company, its player base and its resources, and will be updated as necessary to reflect any novelties in the law.
  2. The training shall include at least:
  • how to identify warning signs and signs of money laundering that arise during the exercise of employees' duties;
  • what to do once the risk is identified (including how, when and by whom to escalate unusual player activity or other red flags for analysis);
  • what employees' roles are in the Company's compliance efforts and how to perform them;
  • the Company's records retention policy;
  • disciplinary consequences for non-compliance with the law.