Last updated: 22 August 2022 ✅
This AML & KYC Policy describes the measures implemented on rira-bet.com to prevent money laundering, terrorist financing, fraud, and other illicit financial activity. The service referenced herein is operated by Ultimate Gaming N.V., registered in Curaçao under company number 159018, with a registered office at Abraham de Veerstraat 9, Willemstad, Curaçao. This document establishes the governance model, technical and organizational controls, and customer-due-diligence (CDD) standards applied across the platform. 🛡️
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Scope, Purpose, and Commitment
Our objective is to deliver a secure environment for all users while meeting applicable international AML standards and high expectations for integrity, transparency, and customer protection. We apply a risk-based approach (RBA) to customer onboarding, monitoring, and review, and we require all personnel to comply with this Policy and its underlying procedures. 📜
Regulatory Baseline and References
- EU: Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.
- EU: Regulation (EU) 2015/847 on information accompanying transfers of funds.
- Sanctions: Applicable restrictive measures on listed persons/entities and embargoed goods/technology, including dual-use items.
- BE: Law of 18 September 2017 on the prevention of money laundering and limitation of cash use (where relevant to cross-border processing).
- Data Protection: Directive 95/46/EC and successor frameworks where applicable to processing of personal data. 🔒
Definition of Money Laundering
Money Laundering (ML) includes: conversion, transfer, concealment, acquisition, possession, or use of property known to be derived from criminal activity; and participation, facilitation, or aiding and abetting in such acts. ML is considered an offense even when the predicate crime occurred in another jurisdiction. ⚖️
Governance and Accountability
- Board-Level Oversight: Ultimate Gaming N.V. Management acts as the “highest level” responsible for AML effectiveness.
- AML Compliance Officer (AMLCO): Charged with policy enforcement, training, reporting, and liaison with competent authorities. The AMLCO reports directly to senior management.
- Change Control: Material updates to this Policy require approval by senior management and the AMLCO prior to implementation.
Customer Lifecycle Controls (Three-Step Verification)
We apply a progressive CDD model. Certain thresholds, channels, and risk indicators trigger enhanced due diligence (EDD). 🧭
Step 1: Core Registration (Required for All Users)
- Required data: first name, last name, date of birth, country of usual residence, gender, and full address.
- Purpose: create a validated baseline identity profile and enable preliminary risk screening prior to withdrawals.
Step 2: Identity Verification (≥ USD 2,000 equivalent in aggregate deposits or withdrawals)
- Government ID check: a photo of an official ID (passport, national ID, or driver’s license) displayed next to a handwritten note showing a six-digit random code.
- Electronic verification: cross-checks against two distinct databases to confirm consistency with Step 1 data.
- Fallback: if e-verification fails, a proof of residence (e.g., certificate of registration by a government authority) must be provided.
- Status: pending deposits/withdrawals/tips are held until Step 2 is completed.
Step 3: Source of Wealth/Funds (≥ USD 5,000 deposits/withdrawals or ≥ USD 3,000 peer-to-peer transfers)
- Source of Wealth (SoW) and Source of Funds (SoF) assessment is required for higher-value activity.
- Illustrative SoW: employment, ownership of business, investments, inheritance, or verified family support.
- Status: pending transactions are held until Step 3 is completed and validated. 🧾
KYC Document Standards
- Photo ID: all four corners visible, clear legibility. The user may mask fields other than first name, last name, date of birth, nationality, gender, and photo. Additional details may be requested as needed.
- Selfie check: a separate face photo may be required to prevent impersonation.
- Proof of Address (PoA): verified via two electronic checks; if not conclusive, provide a recent utility bill, bank statement, or government letter issued within 90 days, with all text readable and all corners visible.
- Payment method matching: withdrawal must follow the original deposit method up to the deposited amount to mitigate ML risk.
Risk Segmentation and Triggers
We categorize jurisdictions and scenarios using a tiered RBA model. Users may be re-classified over time based on activity patterns, payment rails, and sanction screening. 🌍
| Region | Baseline Controls | Thresholds |
|---|---|---|
| Low Risk | Standard three-step verification as described; ongoing monitoring. | Step 2 at ≥ USD 2,000; Step 3 at ≥ USD 5,000. |
| Medium Risk | Heightened verification and earlier SoW/SoF triggers; crypto-to-fiat conversion treated as medium risk. | Step 2 at ≥ USD 1,000; Step 3 at ≥ USD 2,500. |
| High Risk | Onboarding restricted or banned; periodic list reviewed and updated. | Activity not permitted unless otherwise allowed by law and policy. |
Transaction Monitoring and the “Three Lines of Control”
- First Line: trusted Payment Service Providers with effective AML programs, preventing most suspicious deposits before crediting.
- Second Line: internal monitoring combining automated analytics and human review. Customer support and compliance teams conduct due diligence whenever interacting with users about payments, methods, or account changes. 🧩
- Third Line: manual EDD on suspicious or higher-risk users, with potential reporting to the Financial Intelligence Unit (FIU) and competent authorities where required. 🚨
Automated and Human Controls
- AI-assisted anomaly detection supervised by the AMLCO flags patterns such as rapid deposit-withdrawal cycling, mismatched payment instruments, geo/currency volatility, device anomalies, or improbable session behavior.
- Analyst review: experienced analysts validate alerts, request additional documents, or escalate for reporting when warranted.
- Conservative posture: where the lawful origin of funds cannot be reasonably established, the account is restricted or frozen pending resolution. 🧊
Suspicious Activity Reporting (SAR)
Internal procedures define when and how staff report atypical transactions to the AML team. After analysis, the AML team may file a report with the competent FIU under applicable law and, if necessary, terminate the relationship with the customer. 📮
Enterprise-Wide Risk Assessment (EWRA)
We conduct an annual EWRA to assess inherent and residual AML risks across products, user segments, transaction types, delivery channels, and geographies. Control effectiveness, emerging threats, and regulatory developments inform policy updates and control enhancements. 📊
Record Keeping
- Customer identification data: retained for at least 10 years after the business relationship ends.
- Transaction records: retained for at least 10 years after execution or relationship termination, whichever is later.
- Security: data stored securely, encrypted, and protected both online and offline, with access strictly need-to-know. 🗄️
Data Protection and Privacy
Personal data is processed in accordance with applicable data protection frameworks. We do not sell customer data. Information may be shared only when legally required, for the prevention/detection of ML/TF, or to comply with sanctions screening obligations. Users can find additional information about data rights in our privacy communications. 🔐
Training and Awareness
- Mandatory AML training for personnel involved in KYC, payments, or financial decisioning, aligned with the latest regulatory guidance.
- Onboarding education for new employees covering AML fundamentals, red flags, and reporting duties.
- Periodic refreshers and scenario-based exercises coordinated by the AMLCO. 🎓
Policy Enforcement and Consequences
- Failure to complete required verification will result in holds on deposits, tips, or withdrawals until compliance is achieved.
- Use of stolen or third-party payment methods, account sharing, identity misrepresentation, or attempts to bypass controls may result in immediate account suspension or closure and reporting to authorities.
- We reserve the right to request additional documentation at any time based on cumulative risk. ⚠️
Customer Responsibilities
- Provide accurate information and promptly update personal details.
- Use only payment instruments registered in your own name.
- Respond in a timely manner to compliance requests to avoid delays. ⏱️
Examples of Acceptable Source-of-Wealth Evidence
- Employment: recent payslips or a verified employment contract.
- Business ownership: company filings, dividend statements, or audited accounts.
- Investments: portfolio statements or broker confirmations.
- Inheritance/gifts: probate documents or notarized gift statements.
Cash Handling
Where cash deposits or withdrawals are offered, additional controls apply, including stricter identification, SoF documentation, and enhanced monitoring commensurate with heightened risk. 💵
Payments Integrity
- Method mirroring: withdrawals should follow the original deposit route up to the deposited principal to mitigate third-party risk.
- Consistency checks: name on the payment instrument must match the verified account holder’s name.
Contact
If you have questions about this AML & KYC Policy or your verification status, please contact our support team: [email protected]. 📧
Version and Change Log
| Date | Version | Summary of Changes |
|---|---|---|
| 22 Aug 2022 | 1.0 | Initial publication of AML & KYC Policy; three-step verification; EWRA and monitoring model. |
Helpful Notes
- This Policy is part of our broader compliance framework and is reviewed at least annually or upon major regulatory changes.
- Where a conflict arises between this Policy and mandatory law, the stricter requirement applies. 📘