KYC/AML/ATF Policy
Last updated
Last updated
WagerCasino.io
Document Details
Document Owner:
WagerCasino.io
Document Number
1.0
Approved by:
Brendon Dorff
Any questions or suggestions about this document?
AML/ATF Compliance Officer
KYC CRM Manager
Document master located
Version Control
Version
Date
Notes
0.1
September 1, 2024
Draft
1.0
February 4, 2025
Final Approval
This document comprises the Anti-Money Laundering & Anti-Terrorism Financing Program (KYC & AML/ATF Program) implemented by WagerCasino.io (“WagerCasino”).
WagerCasino offers online sports betting on market linked sporting events to registered users.
WagerCasino provides the following ‘Designated Services’ which are covered by this KYC & AML/ATF Program
Item 1
receiving or accepting a bet placed or made by an identified person, where the service is provided in the course of carrying on a business
Item 2
placing or making a bet on behalf of a person, where the service is provided in the course of carrying on a business
Item 3
introducing a person who wishes to make or place a bet to another person who is willing to receive or accept the bet, where the service is provided in the course of carrying on a business
Item 4
paying out winnings in respect of a bet, where the service is provided in the course of carrying on a business or known individual.
Item 5
accepting the entry of a person into a game, where:
(a) the game is played for money or anything else of value; and
(b) the game is a game of chance or of mixed chance and skill; and
(c) the service is provided in the course of carrying on a business; and
(d) the game is not played on a gaming machine located at an eligible gaming machine venue
Item 6
paying out winnings, or awarding a prize, in respect of a game, where:
(a) the game is played for money or anything else of value; and
(b) the game is a game of chance or of mixed chance and skill; and
(c) the service is provided in the course of carrying on a business; and (d) the game is not played on a gaming machine located at an eligible gaming machine venue
Item 7
in the capacity of account provider, opening an account, where: (a) the account provider is a person who provides a service covered by item 1, 2, 3, 4, 6 or 7; and
(b) the purpose, or one of the purposes, of the account is to facilitate the provision of a service covered by item 1, 2, 3, 4, 6 or 7; and
(c) the service is provided in the course of carrying on a business
Item 8
in the capacity of account provider for a new or existing account, allowing a person to become a signatory to the account, where:
(a) the account provider is a person who provides a service covered by item 1, 2, 3, 4, 6 or 7; and
(b) the purpose, or one of the purposes, of the account is to facilitate the provision of a service covered by item 1, 2, 3, 4, 6 or 7; and
(c) the service is provided in the course of carrying on a business
Item 9
in the capacity of account provider for an account, allowing a transaction to be conducted in relation to the account, where: (a) the account provider is a person who provides a service covered by item 1, 2, 3, 4, 6 or 7; and (b) the purpose, or one of the purposes, of the account is to facilitate the provision of a service covered by item 1, 2, 3, 4, 6 or 7; and (c) the service is provided in the course of carrying on a business
As an agent of Anjouan, WagerCasino has obligations under the Proceeds of Crime Money Laundering and Terrorist Financing Act (PCMLTFA) to comply with the AML/ATF Act. As well as KYC (Know Your Customer) requirements as set by the Financial Action Task Force (FATF) as well as local jurisdictions.
Any reference to the reporting entity, ‘WagerCasino or ‘we / us / our’ in this Program is a reference to WagerCasino and any party discharging WagerCasino’s obligations under the KYC & AML/ATF Act on behalf of WagerCasino.
WagerCasino users are all individuals. WagerCasino verifies user identity via iD3Global & GBG verification software or many other intentionally approved services, approved by the jurisdiction we are operating in.
Customer Due Diligence (CDD) has two elements:
Collection of information about the user; and
Verification that the user is the person named in the information material (KYC)
The CDD procedures must enable WagerCasino to:
be reasonably satisfied that an individual user is who he or she claims to be; and
establish whether and to what extent any additional CDD information needs to be collected and /or verified; and
determine what kind of electronic data is reliable and independent for verification purposes; and
respond to discrepancies which may arise when verifying information about a user.
Objective of Player Risk Assessment:
To assess a Player's ML/TF risk
To determine the level of due diligence required with identified level of risk
To determine frequency for ongoing monitoring and player information update
To ascertain the level of management approval required
To help Regulator manage risk mitigation strategies for sector
WagerCasino has adopted a four-tiered risk classification of users and transactions:
low risk
moderate risk
high risk
extreme risk
WagerCasino uses the local government and jurisdiction ‘Player risk-scoring methodology’ for Player Risk Assessments where appropriate. Risk factors are based on the Player information, behaviour, transactional and investigative data on the account.
WagerCasino completes the Player Risk Assessment Scoring Model for each player to substantiate the rating assigned at the point of Player Account Registration and on an ongoing periodic basis to verify any potential changes.
WagerCasino assigns a risk rating of extreme, high, moderate or low based on the player profile information provided and through the assessment of preconditions and other risk factors relevant to each player. Based on this information, the Player Risk Assessment Scoring Model generates a risk score and assigns a corresponding risk rating for each player.
A user is automatically identified as “high risk” if:
user is a Foreign Politically Exposed Person (PEFP)
user is a resident of a high-risk country
user has an association to a high risk occupation and lifetime deposits are greater than €5000
user has 2 or more Suspicious Transaction Reports (STR) submitted to FINTRAC, AUSTRAC or appropriate agency.
A user is automatically identified as “extreme risk” if:
user is barred from local casinos for money laundering and/or terrorist financing reasons
user is considered to be a public safety risk
user is known to be affiliated with organized crime as confirmed by law enforcement
user is a positive match to a sanctions or terrorist list
Any user identified as ‘high risk’ or ‘extreme risk’ by meeting any of the above criteria and any user relationships terminated by WagerCasino due to ML/TF concerns will be reported to the appropriate government body via the “Player High Risk List”.
Furthermore, when a new ‘extreme risk’ user is identified, WagerCasino will notify the governing body in an appropriate agreed time frame.
In identifying its Money Laundering/Terrorism Financing (ML/TF) risk WagerCasino will consider the risk posed by the following factors:
its user types; including: - any politically exposed persons;
its users’ sources of funds and wealth;
the nature and purpose of the business relationship with its users, including, as appropriate, the collection of information relevant to that consideration;
the types of designated services it provides;
the methods by which it delivers designated services
Customer identification consists of two elements:
collection of identity information; and
Verification of information.
The procedures set out in this document apply to the collection and verification of user identity information of new users.
The procedures must be undertaken before the provision of a Designated Service to the user.
WagerCasino only provides Designated Services to individuals and therefore these procedures only cover that customer type.
From time to time, WagerCasino may appoint agents to assist us with discharging our obligations under the KYC & AML/ATF Acts.
Our appointed agents will be responsible for the conduct of all their staff (regardless of the nature of the relationship between the agent and the staff member)
WagerCasino collects data at the account registration stage to confirm the "user type" is an individual as per 2.3 above. WagerCasino only deals with individual clients.
The WagerCasino registration process collects the information as set out in Section 3.1.1 and records the information.
The information recorded is then checked and verified using iD3Global, GBG or equivalent.
If the user is assessed as being of ‘high’ or ‘extreme’ risk, the enhanced customer due diligence requirements (collection and verification) as set out in Section 4 must be undertaken.
Unconditional approval to allow the user commence betting will not be given until WagerCasino are satisfied that the user's identity has been satisfactorily verified.
WagerCasino will retain a copy of:
a record of the procedure to identify a user; and
any information obtained in the course of identifying or attempting to identify a user for at least: - seven years after the document is provided if no Designated Service is provided to the user (e.g. if the user does not engage in trading); or - seven years after the end of the last Designated Service provided to the user (e.g. seven after a product is traded).
Any agents appointed by us may also retain a copy of the information obtained in the course of identifying a user.
WagerCasino will collect the following information about individuals at the time of account registration. If the Player’s identity is not verified in a manner that complies with WagerCasino policy, the account cannot be created. WagerCasino will retain all the records in the Player Account.
WagerCasino will undertake electronic verification using approved identification company id verification software integrated with the WagerCasino platform and will risk rate all players within 30 days of player registration using the player risk assessment methodology.
3.2.1 Procedures for Electronic Verification
a) The WagerCasino platform will collect the information as set out in Section 3.1.1 and verify the information using the dual-process method.
b) Information will be collected and verified from any of the 2 categories and must match the information provided by the Player at registration (see Section 3.1.1); (i) Documents that contain Player name and date of birth (ii) Documents that contain Player name and address or (iii) Documents that contain Player name and confirms they have a deposit account, credit card or other loan account with a financial entity
c) The sources of information must be: (i) Valid and current (ii) Reliable, trustworthy and well-known such as federal, provincial, territorial or municipal levels of government, crown corporations, federally regulated financial institutions or utility providers (iii) The two sources of information must be different and independent of each other (iv) An electronic scanned copy of document can be used
d) Where required the user may be required to enter additional information that may include passport number, drivers license and other information or a scanned copy of such document.
e) Users must accept using these databases. WagerCasino has outlined the use of Electronic Verification in Terms and Conditions.
f) The on-line electronic identification verification provider will either: (i) confirm the identity of the individual from at least two separate data sources (ii) advise WagerCasino that they are unable to verify the player identification of the individual and account registration will be denied
g) WagerCasino will retain a record of the original response from the electronic verification provider used to identify the individual for seven years and will make the following information available upon request to the appropriate body: (i) Player’s full name (ii) Date of identity verification (iii) Name of the 2 different sources used to verify identity (iv) Type of information referred to (e.g. utility statement, bank account info, marriage certificate, etc.) (v) Account or reference number associated with each independent source 3.22 Third Party Determination
WagerCasino will not allow any third party transactions including opening an account OR conducting a transaction on behalf of a third party.
WagerCasino will make a third party determination by taking the following steps:
a) At the time of account registration, Player must confirm whether they are acting on behalf of another individual
b) Player must confirm whether they are acting on behalf of another individual at the time of a transaction trigger including: (i) Making a disbursement of €10,000 or more to the player that requires a Casino Disbursement report (CDR) (ii) Receipt of cash of €10,000 or more for deposit into the player’s igaming account that requires the submission of a Large Cash Transaction Report (LCTR) (iii) An International Electronic Funds Transfer (EFT) of €10,000 or more is made that requires the submission of an Electronic Funds Transfer Report (EFTR)
Where applicable WagerCasino will continue to monitor player activities and transactions for any behaviour that is suspicious and is a potential indicator of ML/TF activity as outlined and requires the submission of a Suspicious Transaction Report (STR) where required.
If a Third Party event is identified, WagerCasino will take reasonable measures to obtain and retain information on the third party including:
Full name including middle name or initial
Alias/preferred name
Full address (not a PO Box or general delivery mailbox)
Date of birth
Email address
Personal telephone number
Descriptive occupation
Country of residence
Citizenship
Employer’s name, telephone number and address
Relationship between player and third party
Person web address
Documentation to identify the person such as number associated with information; jurisdiction and country of issue of documentation; expiry date of documentation
WagerCasino will NOT allow player to open account or for transaction to proceed
WagerCasino will submit Suspicious Transaction Report (STR)
WagerCasino will retain all pertinent information relating to third party activity including description of reasonable grounds to suspect such activity
See Appendix A for Definitions of PEP/HIO and Examples
3.2.3.A WagerCasino will take measures to determine whether a player is a PEP or HIO or related person (see Appendix A for definition) at the point of Player Registration and if any of the following events occur:
Initiation of an international EFT of €100,000 or more on behalf of a player
Receipt of an international EFT of €100,000 or more on behalf of a player
Periodic monitoring of existing igaming account holders
When WagerCasino detects a fact about an existing account holder that indicates a PEP or HIO connection
WagerCasino will take the following reasonable measures to determine if a player is a PEP/HIO or related person:
a) Player Attestation – WagerCasino requires all players to attest to whether they are a PEP/HIO or a related person at the point of account registration and at any point a trigger event takes place as per Section 3.2.3A
b) Name Screening – WagerCasino will screen all player names against the Government Register PEP/HIO database at the point of player registration and on a monthly basis thereafterc
c) Ongoing Monitoring – WagerCasino will review all players for a possible PEP/HIO match when there is an update in the specific government database or if the player updates his/her identification information. Furthermore, WagerCasino will monitor domestic and world events for information that may pertain to new/changed PEP/HIO and screen against existing player lists to identify.
If WagerCasino has reasonable grounds to suspect that a player is a PEP/HIO or related person, additional checks will be performed as outlined as per Enhanced Due Diligence (Section 4). All documentation to support these measures will be retained by WagerCasino in the player’s account and will be available to the governing body upon request.
3.2.4 If PEP/HIO is Identified
If the Player is identified as a PEP/HIO (either domestic or foreign) or a related person, due to any of the above (Section 3.2.3 #1, 2 or 3), the following information will be collected and retained by WagerCasino:
a) Source of Funds and Source of Wealth - to make this determination, the appropriate field is included at the point of self-identifying as a PEP/HIO. Further research will be conducted via public information portals to verify source of funds.
b) Position Description of PEP/HIO
c) Name of organization of PEP/HIO
d) Description of nature of relationship – e.g. if related person, must define nature of relationship
All players identified as PEFP or a related person, will be deemed High Risk and EDD measures in Section 4 will come into force.
All players identified as PEP/HIO or related person, will be assessed using other factors in the Player Risk Assessment review (see Section 5).
WagerCasino will maintain a database of players identified as PEP/HIO or related person and provide a list of all players identified as High Risk to iGO on a quarterly basis and of all players identified as Extreme Risk within 24 hours of identification. (See Appendix J for Regulatory Reporting Timelines)
Senior Management Approval
WagerCasino will do the following upon identification of a PEP/HIO or related person:
a. WagerCasino Senior Manager (CEO, CCO or COO) will approve/deny account registration for identified PEP/HIO or related person within 30 days of determination
b. WagerCasino Senior Manager (CEO, CCO, COO) to review specific event as per 3.2.3 within 30 days
All details regarding name of Senior Manager who provided approval/rejection of account and date of approval/rejection to be maintained in player record.
Enhanced user due diligence procedure will be applied where:
it has been determined that the level of KYC & ML/TF risk associated with the provision of a designated service to the user is ‘high’ or ‘extreme’;
where the user is a PEP/HIO or related person;
where there is a discrepancy in the information provided by the user (or a discrepancy between the information provided by the user and the information revealed by our independent verification processes and cannot be reconciled with additional requests);
where a ‘suspicious matter report’ has been made about the user (within 14 days from when the suspicious reporting obligation first arose); or
A more detailed analysis of the player’s information including, where appropriate,
clarifying or updating or re-verifying information already collected; or
collecting and verifying additional information including, where appropriate taking reasonable measures to identify
A more detailed analysis of the player’s transactions – both past and future, the expected nature and level of transaction behaviour.
For players identified as Extreme Risk, a member of WagerCasino Senior Management (one of CEO/CCO/COO) will approve the termination of the business relationship immediately upon Extreme Risk identification. All information pertaining to this transaction will be retained by WagerCasino.
For players identified as High Risk either at registration or during periodic reviews, WagerCasino will conduct EDD and retain all documentation in the player account. High Risk players will be reassessed every 6 months as part of the ongoing monitoring procedure. See Section 6.
For any player identified as Extreme or High Risk and where a balance of €100,000 or more is deposited into the player’s WagerCasino account, EDD must be conducted within 30 days of account registration the Head of Risk and Fraud, CFO or Equivalent EDD will consist of the following and will be documented on the EDD Checklist form:
date of EDD performed
player identification details (as per 3.1.1)
date the player was last reviewed and risk assessed
confirm player information is up to date
confirm that player activity on WagerCasino platform is continuously monitored
conduct oper source searches to confirm occupation (via social media, online news) and retain documentation
confirm source of funds (see Appendix H)
document any additional measures if taken
Senior management approval (one of CEO/CCO/COO) must then be obtained before WagerCasino provides a designated service to the player and whether WagerCasino will continue to have a business relationship with the player.
Continued monitoring of activity by players assessed as ‘high’ risk to take place every 6 months. All documentation pertaining to any EDD activity to be retained in the player account.
WagerCasino will conduct name screening of all registered players against the PEP list upon registration and then on a monthly basis for the duration of the relationship with the player and then for a period of 5 years from the date of account closure/termination.
See appendix for databases of Sanctions List that WagerCasino will use to screen players.
a. WagerCasino will use all of the identification information provided by the Player to identify positive matches to names on the Sanctions Lists (See Appendix C). See Appendix D for information to be considered to determine if the player's name is a match or not with name on Sanctions List.
b. If not a match, WagerCasino will record rationale supporting determination
c. If it is a positive match to PEP/HIO list, WagerCasino will follow the procedure described in Section 3.2.4
d. If it is a positive match to a terrorist list, WagerCasino will: i. Immediately freeze the account ii. Generate a Terrorist Property Report (TPR) for submission to FINTRAC or appropriate body. iii. Designate one of the CEO/CCO/COO whose authorization is required to unfreeze the account
WagerCasino will maintain all records pertaining to the name screening process at the point of registration and on an on-going basis no matter the result (e.g. even if the result is not a positive match). All documentation and rationale for assessment will be retained in the player account.
WagerCasino will comply with the Ministerial Directives currently in force and with any future Ministerial Directives issued by the Minister of Finance under the provision of the local jurisdiction.
WagerCasino will be notified by the CAMLO at iGO of the issuance of a new directive by the Minister of Finance and comply with all measures indicated in a timely manner as specified by CAMLO.
Current Ministerial Directives in force include:
Every financial transaction originating or bound from either Islamic Republic of Iran or Democratic People’s Republic of Korea to be identified as HIGH RISK and will follow all mitigating measures provided
See Appendix E for Mitigating Measures for all current Ministerial Directives
Using the appropriate Player Risk Assessment methodology, WagerCasino will assess and risk rate all players within 30 days of account registration and periodically throughout the existence of the players’ account with WagerCasino. See Section 6 for frequency of ongoing monitoring.
The objectives of Player Risk Assessment are:
To assess risk of ML/TF
To determine level of due diligence required for player’s identified level of risk
To determine frequency for ongoing monitoring including updating of player information
To determine level of management approval required
To help the Regulator manage risk mitigation strategies with WagerCasino
The following factors trigger an automatic Extreme Risk rating:
Players with history that indicates previous ML/TF activity from local casinos
Players confirmed by law enforcement to be part of or affiliated with Organized Crime
Players positively matched to a Sanctions List or Terrorist List
Any player identified as Extreme Risk as per the above will be evaluated by WagerCasino Senior Management (one of CEO/CCO/COO) for direction to terminate the player account upon execution of Enhanced Due Diligence, within 30 days of the date of knowledge of this information.
The name of any player identified as Extreme Risk will be added to the Player High Risk List report and submitted to the local regulator immediately (within 24 hours of identification). WagerCasino will retain all supporting documentation for determination of risk assessment, senior management decisions and provide to iGO upon request.
The following factors trigger an automatic High Risk rating:
Foreign Politically Exposed Person, their family and/or close associate (see Appendix A for list of PEP/HIO)
Connection to high risk country (see Appendix F for list of countries considered high risk) i. If player is resident of or associated with high risk country ii. Funds sourced from or sent to high risk country
Player associated with high-risk occupation such as cash intensive businesses (see Appendix G for non-exhaustive list of high risk occupations)
Players where 2 or more Suspicious Transaction Reports (STRs) have been filed to FINTRAC. If this occurs after player account has been operational, then player risk assessment must be automatically changed to High Risk
WagerCasino will report all players identified and Extreme Risk, High Risk and accounts terminated due to KYC failure or ML/TF suspicions to iGO via the Player High Risk List. As per 5.1 all players automatically identified as Extreme Risk and those identified as Extreme Risk by the Player Risk Assessment will be reported to iGO within 24 hours of risk determination. WagerCasino will provide a complete list of all players identified as High Risk and Extreme Risk quarterly as per the local Regulators schedule (see Appendix J for Regulatory Reporting Timelines).
WagerCasino will apply EDD for all players identified as Extreme or High Risk.
For players identified as Extreme Risk, WagerCasino will follow the procedure as per section 5.1 and all documentation will be retained in the Player Account including EDD (see EDD Checklist in Section 5.5).
For players identified as High Risk, WagerCasino will conduct EDD at registration and periodically (every 6 months as per Section 6.0) and all documentation will be retained in the Player Account including EDD (see EDD Checklist in Section 5.5).
For all players identified as Extreme and/or High Risk, WagerCasino will complete the following checklist at registration and every 6 months thereafter ensuring all documentation is retained in the player account.
EDD will also be conducted where a balance of €100,000 or more is transferred to the player's WagerCasino account within 30 days of transaction.
Upon identification of a player as either Extreme or High Risk or where there is a transaction/transfer of €100,000 to a player account, a member of WagerCasino Senior Management (one of CEO/CCO/COO) will review EDD Checklist form and approve/deny account registration for players identified as High Risk. WagerCasino will deny account registration for any player identified as Extreme Risk
The EDD Checklist will include the following:
Date of EDD performed
Player identification details (as per Section 3.1.1)
Date the player was last reviewed and risk assessment result
Confirm player information is up to date
Confirm player activities on WagerCasino are continuously monitored
Conduct open source searches to confirm player details and retain search details in player account
Confirm Source of Funds (see Section 5.6)
Document any additional information or measures taken
For all players identified as Extreme and/or High Risk, as well as where a balance of €100,000 or more is transferred to the player WagerCasino account, WagerCasino will conduct EDD to determine source of funds. WagerCasino will:
Ask players to provide information regarding the source of funds. Section 3.1.1, question 5 asks the player’s occupation but for EDD purposes, WagerCasino requires more detailed information. If the explanation is not satisfactory, WagerCasino will request proof such as bank statement, pay stub, etc to support explanation/source of funds.
Conduct open source searches to confirm player’s occupation such as social media (LinkedIn, Facebook, Twitter, TikToketc.) and any publicly available news/announcements. Results of all such searches will be retained in player account
For all players identified as High risk, continued monitoring and updating of player information, including EDD, will be conducted every 6 months automatically, and more periodically. But also manually when funding fluctuates outside the player norm and could be deemed suspicious.
After onboarding, WagerCasino will continue to monitor all players to ensure that all player information is accurate and up to date and also to monitor player activity to detect any unusual and/or suspicious activity. Players will be reassessed and profile will be updated on the following schedule:
a) High-risk player – reviewed every 6 months
b) Moderate-risk player – reviewed annually
c) Low-risk player – reviewed every 2 years
A notification will automatically appear at intervals a/b/c depending on player risk assessment for player to review profile information, make required updates, if necessary and confirm veracity of information. All information to be retained in the player account. WagerCasino must ensure any updates align with player risk assessment and re-assess if necessary.
Periodic assessment review will include:
Any update in player identification information
Result of name screening scan
Details of any regulatory filings on player (UTR/STR/etc)
Ongoing transaction monitoring is being conducted on time
All open source searches conducted
If a player is identified as Extreme Risk, immediate notification must go to a) WagerCasino Senior Management/Board of Directors and b) iGO AML Unit for review and determination of next steps.
Once registered and approved by WagerCasino, all player names will automatically be screened monthly through approved id verification software to ensure PEPs/HIOs/sanctioned people are identified. If there is a positive match, procedure described in Section 3.2.4 to be followed.
All Player information is verified upon signup through the stringent GBG process known as Green ID and meets International KYC requirements. Though the onus is on the customer to keep this information up to date, if WagerCasino are aware of any changes (email bouncing back, or call not connecting) we will suspend the account and contact the customer immediately.
WagerCasino would be looking for suspicious transactions which may be greater than €10,000. But more significantly when a Player’s pattern changes. When a $10 bet Player moves to an average bet size of $100. Or when a Player pattern deviates from a deposit of $300 every Friday, suddenly shifting to $1,500 deposit or frequency of those deposits change.
Player accounts are always monitored in real time, as well as periodically through process checks which could be daily (2am each day) as well as weekly.WagerCasino will exceed any Regulators expectations when it comes to assessing the level of risk for a Player, as we do this on a daily basis. As well as all transactions and activities of a Player’s. Again done in real time and on a daily basis as well as via reporting processes.
WagerCasino will use approved KYC & AML/ATF training modules administered virtually. Training is required for all WagerCasino employees associated with AML/ATF:
upon hire and prior to commencement of job duties
upon return from Leave of Absence (e.g. parental leave)
upon transfer to AML/ATF associated role
senior management and board of directors
as a refresher course annually thereafter for all AML/ATF associated roles and senior management/board of directors
WagerCasino’s Chief Compliance Officer (CCO or COO) is responsible to ensure that all WagerCasino employees associated with AML/ATF, including senior management, fulfil the training program and achieve a minimum score of 80% on AML/ATF Training Test as provided by iGO.
Culminating tests will be administered via email and reviewed/graded by CCO. Failure to complete the test successfully in 3 attempts will result in CCO assessing responses and identifying weaknesses to employees who will be required to take the test again until a passing score of 80% is achieved.
Complete record of training and testing to be retained by CCO for 7 years including:
training dates
training materials used
length of training session(s)
method of delivery
employee name and job title
confirmation of attendance (signed acknowledgement by employee)
testing dates
testing scores
any other relevant information
WagerCasino notes that all dollar amounts refer to Euro currency or its equivalent in foreign currency and will determine reportable thresholds based on current XE.com exchange rates.
WagerCasino has appointed 3 Data Entry Officers (DEOs) responsible for compiling regulatory reports to be submitted to iGO who in turn will submit them to FINTRAC via the secure web reporting system (F2R). They are:
WagerCasino CEO
WagerCasino CFO
WagerCasino COO
See Appendix J for summary of Regulatory Reporting Timelines and Method.
WagerCasino employees will be trained to identify suspicious activity upon hire using the Suspicious Indicators resource (see Appendix I).
If a WagerCasino employees knows or suspects that a player is involved in ML/TF activity, they will generate an Unusual Transaction Record (UTR) which includes the following information:
Unique report identifier number for the UTR
∙ Date of UTR creation
∙ UTR creator name
∙ UTR creator position/job title
∙ Source of referral (e.g., transaction analysis, employee report, Player compliant, etc.)
∙ Unusual/suspicious indicator
∙ Indicator whether transaction was attempted or completed
∙ Transaction date, amount, currency, exchange rate
∙ Player first name, last name, igaming account number, AML risk rating
∙ Investigation steps - document what investigation actions were taken
∙ Supporting documentation - List documents supporting the investigation such as email correspondence, transaction analysis
∙ Resulting action of investigation (e.g., verified, no suspicious activity noted; Suspicious activity noted and STR created)
∙ Provide rationale for STR submitted or not submitted and the date of decision
∙ Assess whether Player risk level requires reassessment based on the decision and record if there was a change or not in the risk rating
∙ Document if an STR was created or not
∙ STR reference number (if applicable)
∙ STR creation date (if applicable)
NOTE: All UTRs will be compiled in UTR log, maintained by the Compliance Officer and provided to iGO upon request.
The WagerCasino employee will refer each UTR to one of the CEO/CCO/COO for review and they will determine if the case requires escalation to generate a STR. Factors to be considered in this determination are:
Assessing the facts and context surrounding the suspicious transaction
Linking ML/TF indicators to the assessment of the facts and context
Screening for and identifying suspicious transactions
Providing explanation for suspicion of STR
If it is reasonable to suspect ML/TF activity, WagerCasino CEO/CCO/COO will create a comprehensive and complete STR as per local Regulator or Governing Body, this applies to both transactions and attempted transactions, and provide all necessary reports.
WagerCasino CEO/CCO/COO will refer to “Suspicious Transaction Report (STR)”.
See Appendix K for guidance on conducting investigation for UTR/STR.
Given our experience in the highly regulated Australian Industry, our solid approach to KYV ML/TF indicators, WagerCasino are confident in identifying STRs of any monetary value no matter how small or large. We understand it's about looking at the whole picture and not just a single transaction.
Given we are able to build a very clear profile of our customers, from average deposit, deposit time lines as well as betting averages, win rates and withdrawal sequences it means the moment a customer steps outside those norms we want to know from a Responsible Gambling perspective, Business perspective as well and just as importantly from a STR perspective which WagerCasino will immediately report to any Regulator as required.
WagerCasino will report all player requested EFTs that fall within the following:
Outgoing EFT in the amount of €10,000 or more leaving the jurisdiction either in a single transaction OR in multiple transactions that total €10,000 or more within a 24-hour period (gaming day) - WagerCasino will generate an Electronic Funds Transfer Report (EFTR) - All EFTRs will be kept for 7 years from date created
Incoming EFT in the amount of €10,000 or more outside of the jurisdiction either in a single transaction OR in multiple transactions that total €10,000 or more within a 24-hour period (gaming day) - WagerCasino will generate an Electronic Funds Transfer Report (EFTR) - All EFTRs will be kept for 7 years from date created
WagerCasino will employ the EFT Travel Rule and ensure the following information is included with information sent or received in an International EFT (either outgoing or incoming). The travel rule information for EFTs includes: a) Name, address and account number of the player requesting the transfer (originator information) b) Name and address of the beneficiary c) If applicable, the beneficiary’s account number or other reference number
If the Travel Rule information is not included with incoming or outgoing EFT, WagerCasino will contact registered players to obtain this information via email or phone.
Transaction will be suspended by WagerCasino senior management (one of CEO/CCO/COO), if information is not made available. Record of incident will be retained in player account profile.
If WagerCasino has grounds to suspect that EFTs could be related to ML/TF activity, a STR will be generated and submitted as per Section 8.1. See Appendices E & F for list high risk jurisdictions (EFTs to and from these jurisdictions require extreme caution) and Appendix I for indicators of suspicious activity regarding EFTs.
WagerCasino will report all disbursements to players that fall within the following:
A Single Transaction in the amount of €10,000 or more within a 24-hour period (gaming day) - WagerCasino will generate a Casino Disbursement Report (CDR) - All CDRs will be kept for 7 years from date created
Aggregated Transactions of 2 or more transactions that total €10,000 or more within a 24-hour period (gaming day) - WagerCasino will generate a Casino Disbursement Report (CDR) - All CDRs will be kept for 7 years from date created
WagerCasino will not complete any transaction that is in any way known or believed to be associated with any form of Terrorist Property (e.g. cash, monetary instruments, igaming accounts, crypto etc).
If in the course of account registration (e.g. match at name screening stage, open source search, etc), WagerCasino learns of any association with or the existence of property owned or controlled by a terrorist group, one of the CEO/CCO/COO will be notified immediately.
The CEO/CCO/COO will in turn:
generate a Terrorist Property Report and provide it to the local Regulator.
STR will also be generated and submitted as per Section 8.1
WagerCasino will retain all TPR for 7 years from the date the report is generated and shared with iGO via Operator SharePoint site.
WagerCasino will terminate player account where:
Player is risk assessed as “Extreme Risk”
Suspicion that player is attempting to use account for ML/TF activity
Changes in customer details which fail KYC
The player account becomes too onerous to manage due to high level of STR reporting
If so directed by BetStop or other Regulatory bodies due to other factors (e.g. new information from other operator re: confirmed suspicious player activity)
Detailed rationale for termination of account will be documented in player account records and provided to iGO with notification of account termination.
All terminated accounts will be deactivated immediately and players will be banned from the ability to create another account on the WagerCasino platform.
Politically Exposed Persons
Foreign Politically Exposed Person (PEFP)
A PEFP is an individual outside of the country who holds an office or position in a foreign jurisdiction.
All PEFP and related people are automatically identified as HIGH RISK clients and thereby subject to Enhanced Due Diligence (EDD)
Examples of PEFP include:
Head of state or government
Member of executive council of government or member of legislature
Deputy minister
Ambassador or counsellor of ambassador
Military officer with rank of general or above
President of state owned entity
Head of government agency
Judge of a supreme court or other court of last resort
Leader of a political party represented in legislature
Domestic Politically Exposed Person (PEDP)
A PEDP is an individual who holds or has held in the last 5 years an office or position on behalf of the federal, a provincial or municipal government. After 5 years, a person ceases to be a PEDP. If PEDP or family members are identified as high risk, EDD measures must be applied.
Examples of domestic offices include:
Governor General, Lieutenant Governor or head of government
Member of Senate or HofCommons or member of a legislature
Deputy minister
Ambassador
Military officer with rank of general or above
President of Crown owned entity
Head of government agency
Judge of provincial or federal court
Leader of a political party represented in legislature
Mayor
Head of an Inter-national Organi-zation
(HIO)
Head of an International Organization (HIO)
An HIO is a person who holds or has held within the last 5 years a specific office or position of head of an international organization and it is either established by the government of states OR is an institution established by an international organization. The HIO is the person who leads this organization such as the CEO or President. If an HIO or family member is identified as high risk, EDD measures must be applied.
Examples of HIO include:
World Trade Organization
World Bank Group
International Monetary Fund
Wealth Health Organization
Family Members of PEDP/PEFP/HIO include:
Mother or father
Children (biological or adoptive)
Spouse or common-law partner
Sibling
Parent of a spouse or common-law partner
Examples of Close Associate of PEDP/PEFP/HIO
Business partner/associate
Are involved in a romantic relationship with PEP/HIO
Are involved in financial transactions
Serve as member of same board
Serve on same charitable initiative
Sanctions Lists for All Player Registrations Note we have referenced Canada, for ease.
a)Public Safety Canada - Listed Terrorist Entities https://www.publicsafety.gc.ca/cnt/ntnl-scrt/cntr-trrrsm/lstd-ntts/crrnt-lstd-ntts-en.aspx
b) United Nations Resolutions on the Suppression of Terrorism https://laws-lois.justice.gc.ca/eng/regulations/SOR-2001-360/FullText.html#h-673021
c) Justice for Victims of Corrupt Foreign Officials Regulations https://laws-lois.justice.gc.ca/eng/regulations/SOR-2017-233/page-2.html#h-842596
d) Justice Laws - Regulations Establishing a List of Entities https://laws-lois.justice.gc.ca/eng/regulations/SOR-2002-284/FullText.html
e) Consolidated Canadian Autonomous Sanctions List https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/consolidated-consolide.aspx?lang=eng
f) Freezing Assets of Corrupt Foreign Officials (FACF) https://laws.justice.gc.ca/eng/acts/F-31.6/
g) Sanctioned Countries https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/current-actuelles.aspx?lang=eng
How to Match Player Name to Sanctions Lists
NAME
if only part of name matches, not a valid match
check all former names/aliases on sanctions list – if a match check against other data such as birthday, address, nationality, etc to determine match
DATE OF BIRTH/AGE
if significantly different in year, month and day, then not a match
if year is same but month/day is different, look for another detail to verify match
NATIONALITY
if nationality doesn’t match, not a match
ADDRESS
ensure not multiple addresses and if address does not match, look for another detail such as nationality/date of birth to verify match
OTHER FACTORS
photograph (if available)
background of player known
open media search
July 25, 2020: Islamic Republic of Iran
This Ministerial Directive requires every financial transaction originating from or bound from, regardless of the amount, to be treated as a high-risk transaction.
Mitigating measures include:
∙ Ensuring that the Player requesting or benefitting from such a transaction, has been identified as per Player identification requirements, including asking for the source of the funds, purpose of transactions and that the information is up to date;
∙ Keeping records of all the above actions; and
∙ Reporting all such transactions to FINTRAC.
Note: While the Ministerial Directive on Iran is not directly applicable for casinos, iGO requires each Operator to adhere to this directive.
December 9, 2017: Democratic People’s Republic of Korea (‘DPRK’)
This Ministerial Directive requires that all transactions to and from North Korea be treated as high risk, regardless of the dollar amount of the transactions.
Mitigating measures include:
∙ Keeping a record of all transactions to and from North Korea, regardless of the dollar amount. This record must include details such as the Player's name, address, date of birth, descriptive occupation and transaction details such as dollar amount, currency, date and type of transaction. These details must specify whether the funds are coming from, or destined to North Korea;
∙ Ensuring that the Player conducting the transaction has been identified as per Player identification requirements, including asking for the source of the funds, purpose of transactions and that the information is up to date;
∙ Conducting enhanced ongoing monitoring of the Player and/or the business relationship and/or the account involved in the transaction;
∙ Keeping records of all the above actions; and
∙ Reporting suspicious transactions to FINTRAC (if applicable).
High-Risk Countries
Albania
Barbados
Botswana
Burkina Faso
Cambodia
Cayman Islands
Haiti
Jamaica
Malta
Mauritius
Morocco
Myanmar
Nicaragua
Pakistan
Panama
Philippines
Senegal
South Sudan
Syria 2
Uganda
Yemen
Zimbabwe
High Risk Occupations Examples
1 Jeweler
2 Pawnbroker
3 Convenience store owner
4 Restaurant Owner
5 Tobacco distributor
6 Foreign exchange
7 Money transmitter
8 Automotive dealer
9 Real estate broker
10 Retail store owner
11 Liquor store owner
12 Cannabis store owner
13 Vending machine operator
14 Privately owned automated teller machines (ATM)
Source of Funds
Obtain source of funds. WagerCasino collects player occupation information upon registration. For EDD, WagerCasino will directly ask players to add information regarding source of funds. If information provided is not satisfactory, WagerCasino will require documentation to prove explanation (e.g. bank statement, pay stub, etc)
WagerCasino will conduct open source searches to confirm player’s occupation and to determine any other information via online news sources such as industry regulators, law enforcement, news media, social media, etc
Ongoing monitoring for all High Risk players will be conducted every 6 months including confirmation of up to date EDD
ML/TF Suspicious Indicators
Summary of Regulatory Reporting Timelines
As Canada is one of our initial jurisdictions we want to enter, this is only an example of the benchmarks we set ourselves. This will be localised for each country we enter.
Data Requirement
Method/Frequency of Transmission to iGO
STR:
Operators will create the STR in F2R within 5 days after establishing that a transaction or attempted transaction is or may be related to the commission of a money laundering or a terrorist activity financing offence and iGO will submit to FINTRAC.
iGO must send an STR to FINTRAC as soon as practicable.
Method: F2R
Frequency: Within 5 days from detection of suspicion
EFTR – Incoming/Outgoing:
Operators will create the EFTR in F2R within 1 day after the day of the transmission of the instructions and iGO will submit to FINTRAC.
iGO must send an EFTR to FINTRAC within 5 working days after the day of the transmission of the instructions.
Method: F2R
Frequency: Within 1 day from transaction date
CDR and LCTR:
Operators will create the CDR/LCTR in F2R within 5 days from the transaction date and iGO will submit to FINTRAC.
iGO must submit a CDR/LCTR to FINTRAC within 15 days from the transaction date.
Method: F2R
Frequency: Within 5 days from transaction date
TPR:
iGO and the Operators must disclose immediately to the RCMP or CSIS the existence of property in their possession or control that they know or believe is owned or controlled by or on behalf of a terrorist group.
The Operator must immediately notify iGO and iGO will file the TPR to FINTRAC (via fax or mail) without delay.
Method: Completed template sent to iGO (via SharePoint) for submission to FINTRAC/RCMP via paper/fax
Frequency: Immediately
As Canada is one of our initial jurisdictions we want to enter, this is only an example of the benchmarks we set ourselves. This will be localised for each country we enter.
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Action
Remarks
1
Complete UTR Log
Complete the UTR Log and ensure all data fields are considered and completed.
2
Review FINTRAC filing history
Search for prior UTRs and STRs that have been filed on the Player.
Exercise additional due diligence when reviewing Player’s that have had previously filed UTRs and STRs.
3
Provide a summary of the unusual/suspicious activity
Describe the activity or circumstances surrounding the suspicion.
4
Review Player information
Review the Player identification information to ensure it is up to date and that the transaction information aligns with the Player information such as occupation.
5
Conduct online searches
Conduct online searches on the Player for relevant news or other publicly available information (Use quotations around names to search the full name, add city/country to narrow the search results if the names are generic).
Check for negative news (e.g. arrests or convictions) and any information that might explain the unusual activity.
Use the name screening tool to search for negative news and/or relevant information.
6
Review transaction history
Review the account activity and assess previous transaction history.
Summarize the type/volume of transactions, source of incoming funds, method of disbursement and note the unusual/suspicious activity observed.
7
Conclusion
No suspicious activity noted – Log the details of the investigation in the UTR that led to this conclusion and close the UTR.
Suspicious activity noted – Provide brief explanation to support the decision and prepare to submit an STR in F2R.
Record the STR number in the UTR Log.
8
Player Risk Assessment
Assess whether Player risk level requires reassessment based on the above decision.
