ANTI-MONEY LAUNDERING AND COUNTERING FINANCING OF TERRORISM POLICY
1. INTRODUCTION
1.1. Context and Purpose of the Policy
Redline Solutions Limited, a company registered in
the Autonomous Island of Anjouan, Union of Comoros registration No.
15884, registered address is at: Hamchako, Mutsamudu, Autonomous
Island of Anjouan, Union of Comoros, who is a holder of Gaming License
No. ALSI-202502005-FI1 (hereinafter also “We”,
“Us”, “Our”,
“Operator” or “Company”).
The Company carries out its operations in jurisdictions where gambling
activity is allowed and complies with gaming and betting license and
the law of Autonomous Island of Anjouan, Union of Comoros.
The Company is not classified as a financial institution under the
applicable laws of Autonomous Island of Anjouan and it is therefore
not directly subject to the statutes and regulations governing
financial institutions, money transfer services or virtual asset
service providers. Gaming services provided by the Company under the
valid gambling license and are directed and provided to individuals
(the “Customers” or “End Users”).
The Company’s cooperation with its service providers, agents,
contractors, external consultants, third-party representatives,
business partners, sponsors, etc. (the
“Counterparties”) and provision of gaming services to
the End Users is transparent, honest and impartial.
Nevertheless, We are fully committed to conducting business with the
highest ethical standards and in strict compliance with all applicable
to our activity laws, particularly those aimed at preventing money
laundering and terrorist financing. Our Anti-Money Laundering
(“AML”) and Counter-Terrorist Financing
(“CFT”) Policy sets out the internal policies,
procedures, and controls designed to identify and prevent possible
risks of money laundering and terrorist financing related to our
operations.
The Company has a zero-tolerance approach to money laundering
(“ML”) and terrorist financing
(“TF”) and is dedicated to complying with all AML and
CTF laws in every jurisdiction where Company operates. This Policy
reinforces Our shared responsibility to follow global anti-money
laundering and counter-terrorist financing regulations and ensures
that Our Counterparties and End Users meet the same high standards. We
are committed to preventing money laundering, terrorism financing, and
any activities that facilitate these illegal actions by upholding all
relevant legal requirements applicable to our activities.
Our business activity is conducted in full compliance with the laws of
Autonomous Island of Anjouan, Union of Comoros (jurisdiction of
Company registration) and other jurisdictions where the Company
operates in accordance with the law, while avoiding restricted
territories, including those that are blacklisted, high-risk or
sanctioned, as outlined in Section 4 of this Policy and Section 6 of
Our Terms and Conditions. This Policy and Terms and Conditions may be
updated periodically in accordance with applicable legislation of
Autonomous Island of Anjouan, Union of Comoros, FATF Recommendations
and the laws of other jurisdictions that may include gambling as a
prohibited activity in accordance with their domestic laws. The
Company independently carries out its B2C activities, serving only the
End Users who are not located in restricted territories.
All terms capitalized and not defined in this Policy have the
corresponding meanings in the Terms and Conditions of the Company.
This Policy covers:
Key business principles of the Company;
Company’s compliance framework, based upon its “three lines of
defense” operating model: the Customer identification, the
Counterparties identification, risk assessment and other AML/CTF
policies and procedures, which include the use of appropriate
programs that ensure proper verification of the Customers and the
Counterparties and ongoing monitoring measures aimed at preventing
the Customers from engaging in illegal and unauthorized activities
and termination of cooperation with the Customers and the
Counterparties in case of detection of illegal and unauthorized
activities;
An overview and revise of the AML/CTF processes and procedures from
time to time depending on legislative requirements;
A description of the key programs and systems employed by the
Company as part of its AML/CTF program;
Verification procedure of the Customers and the Counterparties;
Obligations of employees and third-party service providers who may
be involved in business activity of the Company on how to recognize
activities that may be related to ML and TF; and
Obligations of the Company director to observe and uphold AML/CTF
measures.
1.2. Money Laundering and Terrorism Financing
Money laundering refers to the process of disguising the origins of
illegally obtained funds to make them appear legitimate. It can occur
at any stage of a partnership or business relationship. Crimes such as
corruption, tax evasion, drug trafficking, organized crime, and
embezzlement often generate large profits, which criminals attempt to
legitimize by changing the form of the assets or transferring them to
different countries to conceal their illicit origin.
AML refers to the legal and financial measures designed to prevent,
detect, and report money laundering activities. Regulated entities are
required to implement these controls, with a focus on understanding
the source and destination of funds, especially in operations
involving high-risk factors or regions prone to terrorist financing.
Money laundering occurs whenever assets derived from criminal
activities are used or exchanged. The goal is to evade detection by
authorities and ultimately convert the illegal proceeds into lawful
assets.
Money laundering includes among others:
Dealing in the proceeds of a crime.
Dealing in funds to facilitate a crime.
Concealing the source of illegally obtained money by subsequent
transfers so that it appears to have originated from a legitimate
source.
Advising client on how to structure financial operations to avoid
reporting and recordkeeping requirements.
Willfully or recklessly disregarding the source of a Customer’s
assets or the nature of a Customer’s or Counterparty’s financial
operations.
Money laundering can involve proceeds from a wide range of criminal
activities, such as drug trafficking, securities fraud, bank and wire
fraud, tax evasion, racketeering, terrorism, export violations, and
illegal payments to foreign officials, among others.
The money laundering process typically occurs in three stages:
Placement: the initial introduction of illicit
funds into the financial system, either through physical or
financial transactions, by depositing criminal proceeds into
financial institutions.
Layering: this involves separating the illicit
funds from their criminal origin by executing multiple transactions
to obscure their source. This may include breaking the funds into
smaller amounts or engaging in a series of complex transactions to
disguise the original source.
Integration: at this stage, the laundered funds are
reintroduced into the economics, appearing as legitimate assets.
This process makes the criminal proceeds seem lawful, allowing the
launderer to use them fre
1.3. Some Examples of Suspicious Activities which may be ML
Here are some examples of behaviors that may raise suspicions of ML.
While these actions do not definitively indicate ML, they do warrant
closer examination:
A potential Customer or Counterparty is unwilling to provide
necessary due diligence documentation.
A potential Customer or Counterparty presents due diligence
documentation that is unusual, inconsistent, or suspicious.
A potential Customer or Counterparty does not want to undergo
additional verification.
A potential or current Сustomer or Counterparty is reluctant to
share in the frame of additional verification the information about
the source of wealth and source of funds.
The Customer makes a deposit and immediately without using it
requests a refund of deposit without reason.
A potential Counterparty refuses to disclose the identity of its
ultimate beneficial owner(s) and does not want to provide
verification for the identity or residence of its directors or
authorized representatives.
The Counterparty’s ownership of the business often changes over
extremely short periods of time without any clear business, economic
or legal justification.
1.4. Terrorism Financing
Terrorist acts aim to influence or coerce governments into a specific
course of action or to instill fear in the public or segments of it.
To carry out these acts, terrorists need financial resources, which
can come from both criminal activities (potentially involving elements
of money laundering) and legitimate sources, such as donations from
charities, lawful businesses, or self-funding by individuals.
TF may include activities such as:
Handling funds to support terrorist activities.
Concealing the origin and destination of money through multiple
transfers to make it appear legitimate.
Advising on structuring transactions to evade reporting and
record-keeping requirements.
Willfully or recklessly ignoring the destination of Customer’s
assets or the nature of their transactions.
Assisting in the movement of funds to support terrorism or terrorist
organizations.
Money laundering and terrorist financing share several similarities,
as both involve covert financial activities, often on a global scale.
However, the key difference is that while money laundering seeks to
obscure the origins of illicit funds, terrorist financing focuses on
concealing the intended use or destination of the funds. Terrorists
employ tactics similar to money launderers to avoid detection, protect
the identities of their sponsors, and hide the ultimate recipients of
the funds. Terrorist financing can involve money from legitimate
sources, such as personal donations, business profits, and charitable
contributions, as well as from illegal sources, like drug trafficking,
arms smuggling, and fraud. To transfer their funds, terrorists may use
formal banking systems, informal value transfer networks, and the
physical movement of cash, gold, or other valuable assets through
smuggling channels.
Detecting transactions related to terrorist financing can be just as
difficult, if not more so, than identifying those linked to money
laundering. Since acts of terrorism may not require significant funds
to plan and execute, the amounts involved can be relatively small and
may even come from legitimate sources. As a result, the Company
regularly reminds its employees to stay vigilant. Employees are
expected to ensure that our Customers and Counterparties are known and
identifiable, and that reasonable efforts are made to verify that
transactions between the Company, its Customers and Counterparties are
legitimate and appropriately justified.
1.5. Some Examples of TF Risks
Terrorist organizations may exploit the online gambling industry to
secure funds for planning and executing attacks, training militants,
paying personnel, and spreading their ideologies.
Below are some examples of behaviors that may raise suspicion of TF:
The Customers or the Counterparties are from countries known to
support terrorist activities or organizations.
The Counterparties are using false corporations, including shell
companies.
The Customers or the Counterparties are listed on sanctions lists.
1.6. Objectives
This Policy outlines a comprehensive policy and procedures for risk
assessment and management. It details specific steps to evaluate and
mitigate the risks related to money laundering and terrorist financing
that the Company may face. The Company is fully committed to
preventing any involvement in criminal activities or associations with
criminal entities.
1.7. Purpose of this Policy
The purpose of this Policy is to present the Company’s AML/CTF
policies, framework and controls as well as global AML/CTF policies
and procedures in respect of compliance by the Company of AML and CFT
requirements.
1.8. Application of this Policy
This Policy applies to all individuals working for or on behalf of the
Company in any capacity, including employees at all levels, directors,
officers, agency workers, seconded workers, and interns. It also
extends to the Counterparties, including but not limited to agents,
contractors, external consultants, third-party representatives,
business partners, sponsors or anyone else associated with the
Company, regardless of location.
In any country where the Company operates, local AML/CTF laws and
regulations must be adhered to alongside the requirements of this
Policy. If local laws are less strict than this Policy, the terms of
this Policy should be followed to the extent allowed by local law.
Violations of this Policy may lead to disciplinary action against
employees, termination of business relationship with the
Counterparties or blocking of the Customers, as applicable.
Additionally, breaches of AML/CTF laws may constitute criminal
offenses under relevant laws, potentially leading to prosecution.
2. STANDARDS
2.1. KYC and DD Procedures
The Company has implemented Know Your Customer Procedure
(“KYC”) for its Customers and Due Diligence Procedure
(“DD”) for its Counterparties that are appropriate,
proportionate to the nature and size of its business and tailored to
its business activities.
The Company carries out KYC on all Customers to mitigate the risks of
ML and TF and carries out DD on all Counterparties to mitigate the
risks of ML and TF as well.
KYC and DD are the processes of obtaining information to Know Your
Customer and Counterparty, as a partner (legal entity) and they may
include enhanced KYC measures for the Customers and enhanced DD
measures for the Counterparties for both procedures herein defined as
“EDD”.
The Company applies EDD on a risk-sensitive basis, taking into account
a non-exhaustive list of factors, including the general relationship,
the regularity or duration of the business relationship and geography.
2.2. Requirements to Carry Out DD
DD must be carried out:
Prior to establishing B2B relationship with the Counterparties.
When there is any suspicion of ML or TF during cooperation with the
Counterparties.
For identifying the beneficial owners of the Counterparties and
taking reasonable measures to verify their identity so that the
Company knows who the beneficial owners of the Counterparties are.
For verifying that any person purporting to act on behalf of the
Counterparties is authorized to do so and identifying and verifying
the identity of that person (authorized representative).
For assessing and, as appropriate, obtaining information on the
purpose and intended nature of the business relationship of the
Counterparties.
For conducting ongoing monitoring of the business relationship,
including scrutiny of transactions undertaken throughout the course
of the relationship to ensure that the transactions are consistent
with the Company’s knowledge of the Counterparties, their business
and risk profile and ensuring that the documents, data or
information held are kept up-to-date.
2.3. DD Measures
DD Measures Include:
Identifying the Counterparties, on the basis of provided by them
corporate documents and personal documents of their management,
official representatives and beneficial owners.
2.4. Accepted Documents within the DD
For the Counterparties:
Certificate of Incorporation.
Memorandum and Articles of Association.
Certificate of Incumbency/Excerpt from Commercial Register.
Certificate of Good Standing.
Register of Directors.
Register of Shareholders.
Corporate Structure.
Certificate of Registered Office Address and/or Rental Agreement.
Personal documents (for each Director, Shareholder, Beneficial
Owner, Authorized Representative): proof of ID (international
passport/ID card) and proof of residential address (utility bill,
bank statements, tax bill, rental agreement up to 3 months old).
Source of Funds for UBO (bank statement, payslip, income tax
return), if necessary.
Source of Wealth for UBO (investment portfolio, copy of the contract
of sale, inheritance contract), if necessary.
Power of Attorney for Authorized Representative, if applicable.
Nominee Service Agreement, if applicable.
Indemnity Letter, if applicable.
Declaration of Trust, if applicable.
2.5. Requirements to Carry Out KYC
KYC must be carried out:
After registration by the Customer of their Player’s Account on the
Company’s Website.
2.6. KYC Measures
KYC Measures Include:
Identifying the Customer in accordance with the identification
documents provided by them and verifying their identity using these
documents and data.
Monitoring the risk profile linked to the cryptocurrency wallet used
by the Customer for their Player’s Account.
2.7. Enhanced Due Diligence
The Company may per its own discretion conduct an Enhanced Due
Diligence for the Customers and/or Counterparties if it noticed
something suspicious in the documents provided by them or if the
Company notices any strange activity of the Customer while using the
Services or of the Counterparty during their business relationship.
The Company performs ongoing monitoring of its Customers and
Counterparties in order to detect any behaviors or indicators that
might raise suspicions in regard to ML and TF activities. For this
purpose, the Company has implemented a set of risk indicators that
help it identify such behavior and require the Company to conduct an
EDD to assess information about the Client and Counterparties.
Whenever one of those risk indicators is triggered, the Player’s
Account will be suspended and business relationships with the
Counterparties will be put on hold as well, and the Company will then
initiate EDD procedures.
EDD measures for the Counterparties include:
Checking additional independent, reliable sources to verify provided
information.
Gathering further information about the Counterparties to determine
the Counterparties’ reputation from publicly available information.
Examining the background and purpose of the transaction, as far as
reasonably possible, and taking steps to be satisfied that the
transaction is consistent with the purpose and intended nature of
the business relationship between the Company and the
Counterparties.
Taking adequate measures to establish the source of wealth and
source of funds that are involved in the business relationships or
transactions with the Counterparties.
Increasing the degree and nature of monitoring of the business
relationship in which the transaction is made, to determine whether
the transaction appear to be suspicious.
Re-requesting corporate documents and personal documents of the
management, shareholders and UBO(s).
EDD measures for the Customers include:
Re-requesting identification data of the Customer (full name, place
of birth, country of citizenship, country of residence, residential
address, tax number, if necessary).
Receiving information about the Customer from reliable and
independent publicly available sources.
Obtaining information about the Customer’s source of funds and
source of wealth, if necessary.
The Company may use the third-party services in order to verify any of
the above information provided by the Customer or Counterparties.
The Company will immediately suspend business relationship with the
Counterparties who:
Failed to provide the requested documents and information.
Submitted fraudulent documents and information.
Carry out their business activity in restricted or prohibited
jurisdictions.
Have funds originating from restricted jurisdictions.
Are sanctioned or placed on watch lists from the United States,
European Union, or other global authorities.
The Company will immediately terminate the provision of the Services
to the Customers and block their Player’s Accounts who:
Failed to provide the requested identification documents and
information.
Submitted fraudulent identification documents.
Attempted to deceive regarding their location (using various VPN
means or other technical means).
Are sanctioned or placed on watch lists from the United States,
European Union or other global authorities.
Reside in restricted or prohibited jurisdictions.
Have funds originating from restricted jurisdictions.
Have gambling addiction.
The Company reserves the right to block or suspend the Player’s
Accounts of the Customers or terminate cooperation with the
Counterparties for any other reason at its sole discretion.
2.8. Politically Exposed Persons
A politically exposed person (“PEP”) is an individual
who is entrusted with prominent public functions, other than
middle-ranking or more junior officials, including the following
individuals:
heads of state, heads of government, ministers, and deputy or
assistant ministers.
members of parliament or of similar legislative bodies.
members of the governing bodies of political parties.
members of supreme courts, constitutional courts or other high-level
judicial bodies whose decisions are not subject to further appeal,
except in exceptional circumstances.
members of courts of auditors or of the boards of central banks.
ambassadors, chargés d’affaires, and high-ranking officers in the
armed forces.
members of the administrative, management, or supervisory bodies of
state-owned enterprises.
directors, deputy directors, and members of the board or equivalent
function of an international organization.
Family members of PEP include:
spouse or a person considered to be equivalent to a spouse.
children and their spouses or persons considered to be equivalent to
a spouse.
parents.
PEP known to be close associates mean:
a natural person is known to have joint beneficial ownership of a
body corporate or any other form of legal arrangement, or any other
close business relations, with that politically exposed person.
a natural person who has sole beneficial ownership of a body
corporate or any other form of legal arrangement that is known to
have been established for the benefit of that politically exposed
person.
The following measures will apply to mitigate the risks associated
with PEP Customers and Contractors:
Assessment of the risk posed by PEP Customers and Contractors.
Building the risk profile of the Customers and Contractor including
the online and media search.
EDD measures.
Enhanced on-going monitoring of Contractors activity.
2.9. Transactions Monitoring
Company is fully committed to adhering to the economic and trade
sanctions programs mandated by the jurisdictions where it operates. To
support this commitment, the Company has implemented a transaction
monitoring program equipped with controls and procedures designed to
identify and detect any unusual activity in real-time, as well as
during ongoing monitoring.
The Company conducts regular monitoring using both: internally
developed rule-based systems and third-party solutions to analyze
history of the Customers and Counterparties behavior. This approach
aims to detect and report any suspicious activity and to establish any
necessary additional controls or limits for the Customers or
Counterparties.
The Company has put in place procedures focusing on two essential
aspects of managing unusual or suspicious activity:
Identification of unusual activity: this may occur through inquiries
from law enforcement agencies or reports generated by transaction
and surveillance monitoring systems.
Alert management: this involves processes for investigating,
assessing, and documenting any identified unusual or potentially
suspicious activities.
The Company will implement the following strategies to meet its goals
in the frame of transaction monitoring:
Sanctions Screening: as part of its services, the
Company will screen Customers’ wallet addresses against applicable
sanctions lists using third-party blockchain forensic services. All
cryptocurrency transactions, whether direct or indirect, will be
assessed for potential fraudulent or suspicious activities through
these partners. If any indication of illegal activity is detected,
the Player’s account will be suspended for further investigation.
For accounts identified as high-risk, Customers may be required to
provide sufficient proof of funds as part of the EDD procedure.
Withdrawals to high-risk addresses may be denied after consultation
with our risk assessment partners.
Monitoring for Unusual Activities: the Company will
closely monitor account activities to detect any unusual transaction
sizes, volumes, patterns, or types, while considering relevant risk
factors and warning indicators. Regular reporting will help identify
any high-risk or suspicious activity involving the Customers.
Anti-Mixing Measures: the Company will use
specialized software to identify and analyze suspicious transaction
patterns related to deposits or withdrawals. Each case will be
individually evaluated based on its risk level. Users may be asked
to provide clarification regarding their methods and reasons for
using the platform under these circumstances.
KYC Check at Withdrawal Threshold: If the Player’s
Account reaches a specific withdrawal threshold, the Customer will
be required to pass KYC and/or EDD checks.
The Company also implemented additional monitoring measures as
follows:
Ban Evasion Detection: the Company will utilize
specialized software from third-party providers designed to identify
the Customers attempting to operate multiple accounts. This software
detects connections between accounts accessed using the same
devices. Each case will be evaluated individually, taking into
account the perceived level of risk. Customers involved in such
activities may be required to explain their approach and reasons for
using the Website in this manner. The Player’s Accounts are funded
by the Customers through either local (non-custodial) wallets or
hosted (custodial) wallets. Alongside the third-party provider’s
verification, the Company actively monitors Customers activity on
the Website, ensuring that all findings align with its own
verification processes and those of its third-party service
providers.
IP monitoring system: the Company has implemented a
Player IP Monitoring System that detects information about the
Customer’s devices in order to prevent the participation of the
Customers from prohibited or sanctioned jurisdictions.
Products and Services Review: the Company will put
in place additional measures to prevent the Customers from
attempting to misuse the Website for personal gain. It maintains a
robust set of Terms and Conditions that all Customers must agree to
in order to access the Website. To further reduce the risk of misuse
of the Website by the Customers, the Company may introduce special
policies or procedures. The use of anonymity-enhancing technologies,
such as mixers, tumblers, or certain coins and tokens, is strictly
prohibited. If the Company discovers that any Customer is using
these technologies to increase the anonymity of access to the
Website, they will be immediately blocked.
Third-Party Service Providers: the Company
collaborates with reputable third-party service providers as part of
its compliance and verification processes. It will regularly
evaluate the effectiveness of these key service providers to
determine if additional services or enhancements are necessary. The
Company also conducts DD process on its third-party service
providers, treating them as the Counterparties under this Policy.
3. EMPLOYEES
3.1. Employees Training
A key element in the Company’s efforts to prevent and detect money
laundering is to ensure that its employees are vigilant to the risks
of money laundering and terrorist financing. They must be thoroughly
trained to recognize unusual activities or transactions that could be
considered suspicious.
3.2. Awareness & Expert Training
All employees are required to complete mandatory online AML training
as part of their onboarding process. Furthermore, they must
participate in refresher training sessions on an annual basis. This
training covers relevant AML laws, regulations, as well as the
Company’s internal policies and procedures.
4. RESTRICTED TERRITORY
The Company complies with and does not operate in sanctioned or
black-listed/high risk jurisdictions as well as in those countries
where gambling business is prohibited by law.
The list below is not exhaustive, the list of countries where the
Company does not operate is also presented in Section 6 “Know Your
Client Policy” of the Terms and Conditions.
China,
South Korea,
Malaysia,
Indonesia,
Thailand,
Vietnam,
Philippines,
Saudi Arabia,
Kuwait,
Bahrain,
Oman,
Jordan,
Sri Lanka,
Bangladesh,
Uzbekistan,
Turkmenistan,
Kyrgyzstan,
Tajikistan,
Nepal,
Maldives,
Brunei,
Laos,
Mongolia,
Armenia,
Bhutan,
The United States of America,
Puerto Rico,
Greece,
The United Kingdom (including any overseas territories),
Isle of Man,
Jersey,
Gibraltar,
Spain,
France and its overseas territories (Guadeloupe, Martinique, French
Guiana, Réunion, Mayotte, St. Martin, French Polynesia, Wallis and
Futuna, New Caledonia),
The Netherlands,
Curacao,
Cyprus,
Israel,
Lithuania,
Slovakia,
Belgium,
Dutch West Indies,
Angola,
Albania,
Afghanistan,
Iraq,
Jamaica,
Uganda,
Pakistan,
Islamic Republic of Iran,
Panama,
Lebanon,
Zimbabwe,
Mauritius,
Nicaragua,
Yemen,
Central African Republic,
Côte d'Ivoire,
Sudan,
Liberia,
Syrian Arab Republic,
Cayman Islands,
Somalia,
Congo,
North Korea,
Eritrea,
Haiti,
Sierra Leone,
Ethiopia,
Myanmar,
South Sudan,
South Africa,
Burkina Faso,
Libya,
Mali,
Barbados,
Rwanda,
Czech Republic,
Serbia,
Cuba,
Portugal,
Georgia,
Hungary,
Ukraine,
Estonia,
Bulgaria,
Latvia,
Liechtenstein,
Poland,
Romania,
Turkey,
Russia,
Belarus,
Kazakhstan,
Australia,
Bonaire,
Aruba,
Austria,
The Union of the Comoros,
Germany,
State of Qatar,
The United Arab Emirates,
Japan,
Singapore,
St. Eustatius and Saba,
St. Martin.
All FATF blacklist and all other countries where gambling is strictly
prohibited by law.
Except for the above list, the Company constantly follows and adheres
to the FATF recommendation list.
5. TERMINATION OF BUSINESS RELATIONSHIPS
To reduce the risk of potential unwitting complicity in money
laundering or terrorist financing, We immediately terminate business
relationships with our Customers and/or Counterparties if We become
aware or suspect that they intend to use the Company’s Services for
the purpose of laundering illegal funds or financing illegal
activities.
6. REPORTING
The Company is required to report any unusual or suspicious
transactions in compliance with the Computer Gaming Licensing Act 007
of 2005 and Anjouan Money Laundering (Prevention) Act 008 of 2005. If
the Customer or the Counterparty is identified as being on a sanctions
list or associated with money laundering, terrorist financing, or
other criminal activities, these cases will be reported as suspicious
activities to the Anjouan Gaming Control Board and/or Financial
Intelligence Service (SFI) of the Union of the Comoros.
7. SUMMARY
The Company adheres to strict codes of conduct in order to protect the
Company’s good standing, to instill trust in the Customers and the
Contractors.
In order to comply with regulatory requirements and fulfil its ethical
responsibility the Company warrants that it:
Verifies the Customers and the Contractors prior to establishing a
business relationship and providing Services.
Deals only with the Customers who have registered Account with the
Company (the procedure is additionally defined in the Company’s
Terms and Conditions).
Complies with regulatory requirements and industry best practice.
Does its utmost to ensure that no funds are accepted which originate
from illegal activities.
Prevents all cases when its Services might be used as a tool in ML
or TF.
Ensures effective responsible gambling policies.
The Policy may be amended from time to time to ensure that it remains
harmonized with amendments to legislation and other material
developments originating from changes in international standards. The
Company will notify about amendments to this Policy by posting them on
the Website.