Anti-Money Laundering (AML) Policy

This Anti-Money Laundering (“AML”) Policy sets out how [Company] (“we”, “us”, “our”) works to prevent our services from being used for money laundering, terrorist financing or any other criminal financial activity.

We are committed to operating in full compliance with all applicable laws and regulations on anti-money laundering and counter-terrorist financing, and to maintaining the highest standards of integrity, transparency and responsible conduct in everything we do.

If you have any questions about this AML Policy, you can contact us at:
 Email: [contact email]
 Address: [registered address]

  1. Purpose and Scope

The purpose of this AML Policy is to:

  • Set out the principles and procedures we follow to detect and prevent money laundering and terrorist financing.

  • Describe the responsibilities of our staff and management in relation to AML obligations.

  • Explain what information may be requested from users and why.

This policy applies to:

  • All services provided by [Company] through [Website/Brand].

  • All customers and users who access or use our services.

  • All employees, officers, contractors and agents working on behalf of [Company].

  1. What Is Money Laundering and Terrorist Financing?

For the purposes of this Policy:

  • Money laundering is the process of disguising the illegal origin of funds or assets so that they appear to come from legitimate sources. It typically involves placing, layering and integrating illicit funds into the financial system.

  • Terrorist financing involves providing or collecting funds, by any means, directly or indirectly, with the intention that they be used to carry out terrorist acts or to support terrorist organisations.

Both activities are criminal offences and strictly prohibited. We will not knowingly engage in, or facilitate, any transaction or relationship that is connected with money laundering or terrorist financing.

  1. Our AML Principles

Our AML framework is built around the following core principles:

  1. Zero tolerance for money laundering, terrorist financing and any related criminal activity.

  2. Know Your Customer (KYC) – we verify the identity of our customers and, where relevant, beneficial owners.

  3. Risk-based approach – we apply enhanced measures where the customer, product, geography or transaction presents a higher risk.

  4. Ongoing monitoring – we monitor customer activity and transactions to identify suspicious behaviour.

  5. Timely reporting – we report suspicious activity to the relevant authorities where required by law.

  6. Training and awareness – we ensure our staff receive regular AML training appropriate to their role.

  7. Record-keeping – we keep appropriate records of customer information, verifications and transactions in line with legal requirements.

  1. Customer Due Diligence (CDD) and KYC

To comply with AML requirements, we carry out Customer Due Diligence (CDD) and “Know Your Customer” (KYC) checks on our users. This may include:

  • Verifying identity (e.g. full name, date of birth, residential address).

  • Verifying identity documents (e.g. passport, national ID card, driving licence).

  • Verifying address documents (e.g. utility bill, bank statement, council tax bill).

  • Assessing the source of funds or wealth where appropriate.

We may perform CDD:

  • When you first create an account or register with [Website].

  • When your transactions exceed certain thresholds.

  • When we have reason to suspect money laundering or terrorist financing.

  • When we have doubts about the accuracy or completeness of previously obtained information.

If you do not provide the requested information or documents, or if we cannot verify them to our satisfaction, we may:

  • Refuse to open an account for you.

  • Suspend or restrict your access to our services.

  • Freeze transactions or funds as allowed by law.

  • Close your account.

  1. Enhanced Due Diligence (EDD)

In situations that present a higher risk, we apply Enhanced Due Diligence (EDD) measures. Higher-risk situations may include (non-exhaustive):

  • Customers from, or transactions involving, high-risk jurisdictions.

  • Unusually large, complex or frequent transactions that have no apparent legitimate purpose.

  • Politically Exposed Persons (PEPs) or customers with links to PEPs.

  • Any other scenario where our risk assessment indicates increased AML risk.

EDD measures may include:

  • Obtaining additional identity or address documents.

  • Requesting detailed information about the source of funds or wealth.

  • Conducting more frequent or detailed monitoring of transactions.

  • Seeking approval from senior management before establishing or maintaining the relationship.

If, after applying EDD, we cannot mitigate the risk to an acceptable level, we may refuse to establish a relationship or terminate an existing relationship with the customer.

  1. Ongoing Monitoring of Transactions

We continuously monitor customer activity and transactions carried out through our platform to detect:

  • Unusual patterns of play or behaviour.

  • Transactions that are inconsistent with the customer’s known profile.

  • Sudden changes in bet size, frequency or transaction volume.

  • Attempts to structure deposits or withdrawals to avoid thresholds or checks.

  • Any activity that may indicate money laundering, terrorist financing or other criminal behaviour.

Where we identify suspicious or unusual activity, we may:

  • Request additional information or documentation from you.

  • Temporarily suspend transactions or your account while we review the activity.

  • Report the matter to the relevant authorities in accordance with legal requirements.

  • Decline transactions or terminate the relationship if we believe there is a material AML risk.

  1. Reporting Suspicious Activity

Our employees are required to be vigilant and to report without delay any knowledge or suspicion of money laundering or terrorist financing.

  • We maintain internal reporting procedures so that staff can escalate concerns to our designated AML officer (or equivalent responsible person).

  • Where required by law, we will file suspicious activity reports (SARs) or equivalent notifications with the relevant financial intelligence unit or competent authority.

  • We are legally prohibited from disclosing to the customer or any unauthorised third party that a report has been filed or an investigation is underway (this is commonly referred to as “tipping off”).

We reserve the right to refuse any transaction or to suspend or close any account where we believe, or have reason to suspect, that it may be connected with criminal activity.

  1. Record-Keeping

We keep records in line with applicable laws and regulatory requirements, which may include:

  • Customer identification and verification data (KYC documents).

  • Details of accounts, transactions, deposits and withdrawals.

  • Internal and external reports made in connection with suspicious activity.

  • Correspondence and any other information relevant to AML compliance.

These records are usually retained for a minimum period required by law (for example, five years from the end of the business relationship or the date of the last transaction), and may be kept for longer where there is an ongoing investigation or legal requirement.

All personal data is processed in accordance with our Privacy Policy and applicable data protection laws.

  1. Politically Exposed Persons (PEPs)

A Politically Exposed Person (PEP) is an individual who is, or has been, entrusted with a prominent public function, as well as their immediate family members and close associates.

Because PEPs may present a higher AML risk, we will:

  • Take reasonable steps to identify whether a customer or beneficial owner is a PEP.

  • Apply Enhanced Due Diligence where a PEP relationship is identified.

  • Obtain approval from senior management before establishing or continuing a relationship with a PEP.

  • Conduct more frequent monitoring of the relationship.

If we are unable to manage the associated risks to our satisfaction, we may refuse to establish or continue a relationship with a PEP.

  1. Training and Awareness

We recognise that effective AML compliance relies on knowledgeable and vigilant staff. We therefore:

  • Provide AML training to relevant employees at induction and at regular intervals thereafter.

  • Ensure staff understand their legal obligations and internal procedures.

  • Update training materials to reflect changes in law, regulation, guidance and our own risk assessments.

  • Encourage a culture of compliance, where employees feel comfortable raising concerns in good faith.

Failure by staff to comply with this Policy or to follow AML procedures may result in disciplinary action, up to and including termination of employment, and may expose individuals to personal criminal liability where applicable.

  1. Risk-Based Approach

We adopt a risk-based approach to AML compliance. This means we:

  • Assess the AML and CTF risks associated with our products, services, customer types and geographical footprint.

  • Implement controls that are proportionate to the level and nature of the identified risks.

  • Review and, where necessary, update our risk assessments periodically or when there are significant changes (e.g. new products, markets or regulations).

By focusing resources where the risks are higher, we can operate more efficiently while maintaining robust AML defences.

  1. Use of Third-Party Providers

In some cases, we may use third-party service providers to assist with:

  • Identity verification, document checks and KYC screening.

  • Sanctions and PEP screening.

  • Transaction monitoring and fraud detection.

Where we engage such providers, we:

  • Conduct appropriate due diligence on their capabilities, controls and reputation.

  • Ensure contractual arrangements clearly set out data protection and confidentiality obligations.

  • Monitor performance and compliance with our standards and legal requirements.

Responsibility for AML compliance remains with [Company], even when third parties are used.

  1. Sanctions and Prohibited Transactions

We comply with applicable international sanctions regimes, including those imposed by the:

  • United Nations

  • United Kingdom

  • European Union

  • Other relevant competent authorities

We will not enter into or maintain relationships with customers, entities or countries that are subject to comprehensive sanctions, or where this would expose us to unacceptable legal or reputational risk.

We may:

  • Screen customers and transactions against sanctions lists.

  • Refuse or cancel transactions that involve sanctioned persons, entities or jurisdictions.

  • Report relevant information to authorities where required by law.

  1. Cooperation with Authorities

We cooperate fully with:

  • Law enforcement agencies

  • Financial intelligence units

  • Regulatory authorities and other competent bodies

when they request information or assistance in connection with AML and CTF investigations, subject always to our obligations under data protection and privacy laws.

Where legally permitted and appropriate, we may also cooperate with other regulated institutions to help combat money laundering and terrorist financing.

  1. Customer Responsibilities

Our customers also have an important role to play in preventing money laundering and terrorist financing. By using our services, you agree to:

  • Provide accurate, complete and up-to-date information when requested.

  • Not use our services for any illegal purpose or in connection with any criminal activity.

  • Not attempt to conceal the origin of funds or to mislead us regarding the source of funds or wealth.

  • Cooperate with any requests for additional information or documentation relating to your account or transactions.

If we believe you have provided false or misleading information, or are using our services for unlawful purposes, we may:

  • Refuse transactions

  • Suspend or close your account

  • Report our concerns to the relevant authorities

  1. Review and Updates to this AML Policy

We review this AML Policy periodically and may update it at any time to reflect:

  • Changes in applicable laws and regulations

  • Updates to regulatory guidance or industry best practice

  • Changes in our products, services or risk profile

Any updated version will be published on [Website] and will take effect from the date of publication. We encourage you to review this Policy from time to time to ensure you remain informed about how we combat money laundering and terrorist financing.

  1. Contact Us

If you have any questions or concerns about this AML Policy or our AML practices, you can contact us at:

  • Email: [contact email]

  • Postal address: [registered address]

  • Contact form: [link to contact form, if applicable]