Anti Money Laundering Policy of Pin Up Casino Bangladesh
1. Preamble
1.1 Decontaminating Capital
Decontaminating Capital (DC) delineates the methodologies employed to mask the origins of monies amassed from unlawful enterprises such as narcotics trafficking or extremist operations, suggesting that these funds derive from reputable sources. Culprits obfuscate the origins, alter the form, or relocate the assets to less scrutinized locales to camouflage their illicit activities.
1.2 Counteractive Measures against Money Laundering
Counteractive Measures against Money Laundering (CMML) refers to the statutory and fiscal protocols mandating that financial bodies and other regulated entities inhibit, detect, and document DC activities. A robust CMML framework compels a jurisdiction to:
- Criminalize the act of Decontaminating Capital
- Empower regulators and law enforcement with necessary investigative tools
- Mandate financial institutions to recognize their clientele, institute risk-adaptive controls, preserve records, and report any dubious transactions
- Facilitate data exchange with counterpart jurisdictions as needed
2. Oversight
Employees within the remote gaming sector must report any information received during their professional duties when:
- They are certain,
- They suspect,
- They have justifiable reasons to believe that an individual is involved in money laundering or terrorist financing, including illicit expenditures.
These prerequisites are collectively termed as the basis for knowledge or suspicion. The regulators seek proof that a risk evaluation was performed before establishing business relations with clients and that thorough customer due diligence was conducted to align customer transactions with their risk profile.
Merchants must demonstrate that their ongoing monitoring is conducted on a risk-sensitive basis and all records are maintained to reflect this, with risk profiles diligently updated. In this document, we highlight additional strategies employed to enhance risk monitoring and identify scenarios necessitating a Declaration of the source of funds from customers in high-risk situations.
2.1 Particular Ordinances
The Merchant commits to integrating compliance across all business facets, upheld by a licensed Curacao Gaming License facilitating the operation of Internet-based Games of Chance internationally.
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3. Criminal Activities & AML Strategies
The AML framework is constructed upon principles and practices:
- Development of appropriate systems and controls to meet legal and regulatory standards
- Annual assessment of AML risks inherent in the business model; subsequent adoption of a flexible, effective, proportionate, and cost-efficient risk-based approach
- Firm commitment and accountability from senior management
- Routine evaluation of the effectiveness of systems and controls
- Maintenance of comprehensive records to support law enforcement agencies in tackling money laundering and terrorist financing
- Provision of initial and ongoing training to all pertinent staff
- Support for the appointed officer with sufficient resources and authority to function independently
4. Risk Administration
We adhere to specified policies and procedures for risk assessment and management as stipulated by the Money Laundering Regulations of 2007. This risk-centric methodology entails several discrete steps:
- Identification of relevant money laundering and terrorist financing risks
- Formulation and implementation of strategies to manage and mitigate these risks
- Continuous monitoring and refinement of these controls
- Documentation of actions taken and rationales
5. Dubious Activities
Referring to dubious transactions, extreme player profiles, and disparities in deposits among other indicators. We outline procedures for risk monitoring of our customers and when enhanced due diligence is imperative:
- Passport or ID card
- Utility bill
- Bank statement
- Additional proof of identity
Enhanced Due Diligence is contingent on the player’s profile and the associated risk they pose. Identification of certain criteria or a combination thereof will trigger a flag on the customer(s) for further risk monitoring.
5.1 Reports on Dubious Activities (RDAs)
Within our framework, RDAs are mandatory. Any employee who identifies grounds for suspicion of ML or terrorist financing must report to the Risk Team. Failure to do so may result in criminal charges.
Discretion is vital in escalating RDAs, preferably through handwritten means to maintain anonymity. Employees must never disclose any AML-related concerns to the investigated individuals or others, as such disclosure could incur severe legal consequences.
Furthermore, our protocol dictates that no remarks that might suggest suspicion of ML should be recorded on a customer’s account since a customer could request to see all comments at any time.
5.2 Examination Procedures
Before processing withdrawals, we review the customer’s deposit history to ensure no suspicious transactions have occurred. We also evaluate the customer’s turnover to confirm genuine participation in games rather than using our services for money laundering.
When feasible, refunds should be issued through the original payment method used by the player. This ensures the integrity of the financial transactions and complies with regulatory standards.
6. Personnel
6.1 Executive Leadership
Our executive leadership is deeply engaged in and responsible for the implementation of this policy. They understand their personal legal liabilities related to the commission of offences under the Regulations, whether through direct involvement or negligence.
6.2 Money Laundering Reporting Officer (MLRO)
Our designated MLRO, Nikos Lazos ([email protected]; +35780077001), is responsible for managing RDAs concerning the prevention and detection of money laundering and fulfilling our obligations under various legal frameworks. The MLRO operates with independence and is well-resourced to perform their duties effectively.
6.3 Educational Initiatives
All staff undergo training on their obligations regarding money laundering reporting. They are familiarized with the internal procedures for escalating any suspicious activities to the MLRO. This training also emphasizes the legal repercussions of ignoring the requirements, such as potential criminal or regulatory actions.