AML

AML POLICY

In the context of this policy, money laundering refers to:

a. the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;

b. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

c. the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;

d. participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points (a), (b) and (c).


Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Terrorism financing means : the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out any terrorist act.

The GWbet.com AML Policy is designed to prevent money laundering by meeting European standards as well as international standards, such as the recommendations and papers from the Financial Action Task Force (FATF).

The AML Policy includes the following minimum standards which must be complied with:

  • Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;

  • Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as politically exposed persons (PEPs) and sports exposed persons (SEPs);

  • Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;

  • Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

  • Maintaining appropriate records for the minimum prescribed periods;

  • Providing training for and raising awareness among all relevant employees.

KYC POLICY

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC (know your customer) policy.

The KYC principle begins with identification of the customer by means of the necessary identification documents. That identification, completed by other information gathered, enables the Customer Acceptance Policy to be applied. In addition to these objective criteria, there are subjective elements which may arouse suspicion regarding a customer and to which particular attention should be paid. Finally, as KYC does not involve static data, but dynamic data through the relationship with the customer, it also needs follow-up and ongoing monitoring of the customer.

The customer identification relies on the following fundamental principles:

  • The acceptance policy is applied to any person or entity willing to use our betting services, or products. As a general rule, customers who may be accepted by GWbet.com are persons (in case of betting players) or entities (in case of commercial partners):

    • fully identified in accordance with the company’s procedures, and
    • in case of entities with a sustainable source of income, and
    • when such financial relations will be active, diversified and over the long term.

  • Each customer (= each individual person and/or each person involved in the case of a legal entity) must be identified by means of original supporting documents. GWbet.com can request additional documents from the customer if there is reasonable doubt regarding the customer’s identity.

  • These documents will be recorded in a centralised system.

  • Each person identified must be registered by IT means.

  • A person will not be accepted as a customer if the identification process proves to be incomplete. The specific case of the due diligence is exercised on the acceptance of politically exposed persons (PEPs) and sports exposed persons (SEPs).

  • The decision of GWbet.com to reject a customer due to reasonable doubt regarding their identity is final.