Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy for 포모 카지노

1. Introduction

1.1. Overview

This AML and CTF Policy ensures 포모 카지노 complies with the gambling license requirements set by the Tobique regulations.

1.2. Scope

The policy applies to all 포모 카지노 staff involved in services that could potentially be used to conceal the origins of illicit proceeds, aiming to make unlawful funds appear legitimate.

1.3. Requirements

We maintain robust policies, procedures, and controls to identify, assess, and reduce the risk of Money Laundering (ML) and Terrorist Financing (TF). This includes:

• Compliant policies and procedures per regulatory standards
• Customer Due Diligence (CDD) conducted on the first withdrawal request or within 30 days of the first deposit
• A system for reporting suspicious transactions (STR)
• Document retention protocols
• Annual AML training for all relevant staff

1.4. Risk Management Framework

We implement a comprehensive ML/TF risk management framework across all markets to prevent, detect, and report suspicious activity.

2. Regulatory Framework

2.1. Legislation and Regulations

포모 카지노 follows these AML/CTF regulations:

• Tobique gaming commission regulations
• Guidelines from the Financial Action Task Force (FATF) and the Asia/Pacific Group on Money Laundering (APG)

3. Money Laundering and Terrorist Financing Definition

3.1. Money Laundering

Money laundering is the process of disguising the true origin of criminal proceeds. It involves three stages:

• Placement: Injecting illicit funds into the financial system
• Layering: Hiding the connection between funds and their criminal origin
• Integration: Converting illicit funds into legitimate assets

3.2. Company Policy

포모 카지노 does not accept cash payments, focusing on preventing the use of its platform for money laundering during the layering and integration stages.

4. Purpose and Scope

4.1. Mandate

포모 카지노 is required by AML regulations to identify and mitigate risks associated with criminal activities, applying this policy to all clients under the Tobique license.

5. Business Risk Assessment

5.1. Risk Factors

We assess risks based on:

• Customer and transaction risk
• Product and payment risks
• Geographical and delivery risks

5.2. Review Process

Our risk assessment and AML/CTF policy are reviewed annually or in response to:

• Regulatory or legislative changes
• New guidance or best practices
• Findings from audits or internal reviews

6. Compliance Officer/MLRO

6.1. Responsibilities

Our Compliance Officer/MLRO is tasked with:

• Identifying high-risk ML/TF situations
• Maintaining records of risk assessments and management policies
• Reporting to senior management on the effectiveness of AML procedures

7. Customer Due Diligence (CDD)

7.1. KYC Procedures

New customers must provide:

• Full name, residential address, country of residence, date of birth, and email address

7.2. Risk-Based Verification

CDD measures are applied based on customer risk, with higher-risk customers subject to enhanced checks, including:

• Verification of identity and address
• Verification on first withdrawal or within 30 days of the first deposit

8. Enhanced Due Diligence (EDD)

8.1. When EDD is Required

EDD is triggered in cases such as:

• Suspicion of ML/TF
• Concerns about customer data adequacy
• Inconsistencies with customer profiles

8.2. Required Documentation

Customers may be asked for:

• Payslips, bank statements, tax returns, company financials, savings documents

9. Internal Controls

9.1. Daily Monitoring

Internal controls include reports on:

• First-time deposits, high deposits, and high balances
• Device and address links
• High-risk countries and third-party funding

10. Ongoing Monitoring and Due Diligence

10.1. Transaction Monitoring

All transactions are monitored for unusual patterns, and daily reports help identify suspicious activity.

10.2. Ongoing Due Diligence (ODD) and Enhanced Ongoing Due Diligence (OEDD)

High-risk customers are monitored regularly, and CDD/EDD measures are updated as necessary.

11. Due Diligence for Third Parties/Clients

11.1. Required Documentation

Third-party clients must provide:

• Ownership and control structure, corporate chart, CDD for UBOs and directors, corporate DD docs, share registers, and company license (if applicable)

11.2. Screening

UBOs, directors, and signatories are screened against PEP, sanctions, and adverse media lists. Relationships are terminated if any matches are found.

12. Counter-Terrorist Financing (CTF)

12.1. Sanctions List Screening

All customers are checked against sanctions lists, and accounts are closed if found.

12.2. Ongoing Screening

Regular re-screening of customers against sanctions lists ensures compliance.

13. Politically Exposed Persons (PEP)

13.1. PEP Screening

Customers are screened against PEP lists, and if identified as a PEP, additional verification steps include:

• MLRO approval, source of wealth verification, and enhanced monitoring

14. Adverse Media List

14.1. Screening

All customers are checked against adverse media lists, and the Compliance Officer/MLRO will investigate any necessary terminations.

15. Persons Connected to Sporting Events

15.1. Risk Management

포모 카지노’s system identifies customers linked to sporting events, teams, or associations, including events on which we accept bets.

16. Threshold Transaction Reporting

16.1. Reporting Requirements

Transactions over 10,000 CAD are reported to the relevant authorities within 10 business days.

17. High-Risk Jurisdictions

17.1. Geographical Risk Assessment

Countries are assessed based on FATF, APG, and Basel AML Index lists. Customers from high-risk regions undergo additional scrutiny.

17.2. EDD for High-Risk Customers

Customers from high-risk countries must provide CDD, with EDD possibly triggered by nationality, country of birth, or transaction behavior.

18. Record Keeping

18.1. Document Retention

Records are retained for a minimum of five years after the end of the business relationship or transaction.

19. Suspicious Transaction Reporting (STR)

19.1. Legal Responsibility

포모 카지노 is required to report suspected ML/TF activity to the relevant commission.

19.2. Internal Reporting

Employees must report suspicions using an Internal STR form submitted to the Compliance Officer/MLRO.

19.3. Review and Action

The Compliance Officer/MLRO will investigate and take appropriate action, including reporting externally if necessary.