Aml

Policy Statement

Ffbet is committed to preventing the use of its gaming services for money laundering, the financing of terrorism, or proliferation financing. This policy establishes the anti‑money‑laundering (AML) and countering the financing of terrorism (CFT) framework the Company applies in all customer onboarding, account management, and payment activities. It reflects the requirements of the Curaçao Gaming Control Board and applicable international standards, and it adopts a risk‑based approach to identify, assess, and mitigate ML/TF/PF risks.

Purpose

The purpose of this policy is to describe the principles, requirements, and procedures the Company uses to detect, prevent, and report suspicious or adverse financial activities. It sets out the responsibilities of personnel, the process for ongoing risk assessment, and the controls implemented to ensure compliance with applicable laws and regulatory expectations.

Scope and Audience

This policy applies to all employees, contractors, and any third parties acting on behalf of Ffbet who participate in customer onboarding, payment processing, or other activities subject to AML/CFT obligations. It also covers senior management and the Board of Directors responsible for governance and oversight of AML/CFT controls.

Definitions

  • Money Laundering (ML): The process of concealing the illicit origin of funds by introducing them into the financial system through stages of placement, layering, and integration.
  • Terrorist Financing (TF): The provision or collection of funds with the intention that they be used to support terrorist acts or organizations, regardless of the origin of funds.
  • Proliferation Financing (PF): The financing or provision of services used for the development, acquisition, or transfer of weapons of mass destruction or their delivery systems, in violation of international obligations.
  • Customer Due Diligence (CDD): The process of identifying and verifying customer identity, understanding the purpose and nature of the business relationship, and monitoring the relationship and transactions.
  • Enhanced Due Diligence (EDD): Additional verification and scrutiny applied in higher‑risk situations, including PEPs or customers from high‑risk jurisdictions.
  • Politically Exposed Person (PEP): An individual who holds or has held a prominent public function, including immediate family and close associates, posing higher ML/TF risk.
  • Sanctions Screening: Checking customers and transactions against national and international sanctions lists and PEP databases.
  • Beneficial Owner: The natural person who ultimately owns or controls a customer or the person on whose behalf a transaction is conducted.
  • Unusual Transaction Report (UTR): A reporting obligation to the competent authority when a transaction is deemed suspicious or abnormal.
  • Risk‑Based Approach (RBA): A strategic framework that tailors controls to the level of ML/TF/PF risk associated with the customer, product, service, or channel.

Policy Governance and Compliance

The Company maintains governance structures to oversee AML/CFT controls, including a Compliance Officer and senior management oversight. The Curaçao Gaming Control Board may request information or access to records, and the policy is subject to periodic review and updates. The Board approves material changes, and the Compliance Department maintains documentation and records for regulatory inspections and audits.

AML/CFT Framework

The framework implements a risk‑based program comprising risk assessment, customer due diligence, enhanced due diligence where warranted, customer acceptance controls, ongoing monitoring, and suspicious activity reporting. Controls are designed to operate across onboarding, payment processing, and account management activities.

5.1 Business Risk Assessment (BRA)

The Company conducts a documented BRA to identify, evaluate, and mitigate ML/TF/PF risks arising from products, services, delivery channels, customers, and geographies. The BRA considers the following factors:

  • Customer risk characteristics, including source of funds and spending patterns;
  • Product, service, and transaction risk associated with gaming offerings and payment methods;
  • Delivery channel risk, including non‑face‑to‑face onboarding and third‑party intermediaries;
  • Geographical risk, including sanctions status and regulator expectations;
  • National and regulatory risk assessments (NRA) and applicable FATF/CFATF guidance;
  • The Company’s risk appetite and mitigation controls appropriate to identified risks.

The BRA is approved by the Board, maintained by the Compliance Department, and available for regulatory review upon request. It is reviewed at least annually or upon material changes to products, processes, or regulatory expectations.

5.2 Customer Risk Assessment (CRA)

During onboarding or prior to a significant transaction, the Company conducts a CRA to determine each customer’s ML/TF/PF risk level and the corresponding CDD level. CRA factors include:

  • Customer risk: Source of income, financial behavior, red flags (e.g., multiple income sources, unverifiable funds, unusual spending).
  • Geographical risk: Residence, nationality, and origin of funds; presence on sanctions or high‑risk lists.
  • Product/service/transaction risk: Exposure to high‑risk payment methods, peer‑to‑peer activity, or multi‑site account usage.
  • Distribution channel risk: Non‑face‑to‑face onboarding, use of intermediaries, or anonymous channels.

The CRA outcome informs the applicable CDD measures and ongoing monitoring requirements. The CRA methodology and customer risk profiles are documented, maintained by the Compliance Department, and subject to regulatory audit.

5.3 Customer Acceptance Policy (CAP)

The CAP defines criteria for accepting and maintaining business relationships. It aligns acceptance with the customer’s risk profile and the Company’s CDD regimes. Core elements include:

  • a) Risk‑Based Acceptance Criteria: Categories of customers with elevated ML/TF/PF risk, indicators for risk tiering, CDD obligations per tier, and triggers for enhanced due diligence.
  • b) Sanctions and PEP Screening: Screening against UN/EU sanctions, Curaçao‑published lists, PEP databases, and reputable sources; senior management approval and funds source verification required for PEPs or sanctioned individuals.
  • c) Grounds for Declining or Terminating the Relationship: Inability to complete CDD, submission of unverifiable documentation, links to sanctioned entities, or suspected criminal activity.
  • d) Documentation and Governance: Board approval for CAP; oversight by the Compliance Officer; all decison records with rationale; annual CAP reviews or as risk indicators change.

5.4 Customer Due Diligence (CDD)

The Company applies robust, risk‑based CDD to identify and verify customers, understand the purpose of the relationship, and monitor activity. Triggers for CDD include:

  • Financial transactions equal to or above NAf 4,000;
  • Occasional transactions exceeding NAf 4,000 (individually or as linked series);
  • Suspicion of ML/TF or concerns about information accuracy or completeness.

CDD measures comprise:

  • Identification and verification of the customer: full name, residential address, date and place of birth, nationality, and identity number;
  • Verification through valid government‑issued documents with photo evidence;
  • Address verification where required (utility bill or bank statement, not older than six months);
  • Additional verification methods when necessary: biometric validation, video verification, geo‑location/IP data checks, and device fingerprinting;
  • Customer risk assessment at onboarding to assign initial risk rating;
  • Understanding the purpose and expected nature of the relationship, including source of funds/wealth documentation in higher risk cases;
  • Ongoing sanctions and PEP screening on onboarding and periodically thereafter, with enhanced monitoring for PEPs or sanctioned customers;
  • Freezing of funds and reporting obligations if documentation is not provided within 30 days after reaching the NAf 4,000 threshold; suspension of deposits/withdrawals; funds returned to source except where ML/TF is suspected and a report is filed; processing may be suspended if completing CDD could tip off an investigation; in such cases a report may be filed with the FIU without customer contact.

5.5 Enhanced Due Diligence (EDD)

EDD is applied when the ML/TF/PF risk is assessed as higher. EDD involves intensified verification and ongoing monitoring, additional documentation requirements, closer scrutiny of source of funds and wealth, enhanced transaction monitoring, and frequent review of the customer profile. EDD decisions are documented and approved by appropriate senior management based on the risk assessment.