Anti-Money Laundering Policy
Last updated on: 07.08.2026
1. Introduction
1.1 Money Laundering
Money Laundering (ML) is the process of creating the appearance of funds obtained from criminal activity, such as drug trafficking or terrorist activity, being originated from a legitimate source. Criminals attempt to launder money by disguising the source and/or changing the form of the funds, or moving them to a place where they are less likely to attract attention.
1.2 Anti-Money Laundering
Anti-money laundering (AML) is a financial/legal term used to describe the legal controls that require financial institutions and other regulated entities to prevent, detect, and report ML activities.
An effective AML program requires a jurisdiction:
To have criminalized Money Laundering
To have given the relevant regulators and police the powers and tools to investigate it
To have its financial institutions identify their customers, establish risk-based controls, keep records and report suspicious activities
To be able to share information with other jurisdictions as appropriate
2. Regulation
Employees working in the remote gaming industry are required to make a report in respect of information that comes to them in the course of their business:
These obligations are collectively referred to as grounds for knowledge or suspicion. What the authorities are looking for is that we are able to demonstrate, with supporting evidence, that a risk assessment is and has been undertaken prior to entering into business relationships with customers and that adequate customer due diligence is conducted in order to ensure that customers' transactions are consistent with the level of risk presented.
The Merchant must be able to demonstrate that the extent of the ongoing monitoring undertaken is conducted on a risk-sensitive basis and that all the records are retained by us to reflect this, with risk profiles being properly maintained. In this document, we have identified additional measures that are being applied in order to carry out risk monitoring and the need of where we would require a Declaration of the source of funds from customers in situations which present a high risk and potentially money laundering.
2.1 Specific Regulations
The Merchant is committed to ensuring that compliance is embedded in all aspects of our business and licensed Anjouan Gaming License that allow the operations of Games of Chance on the International market via service lines.
3. Crime & Disorder and AML Policy
AML policy is based on principles and practises:
We develop systems and controls that are appropriate for our businesses and comply with legal and regulatory requirements
We assess the AML risks inherent in our current business at least annually; we then adopt a risk-based approach that is flexible, effective, proportionate and cost effective
We have full commitment for this from, and responsibility resting with, senior management
We regularly assess the adequacy of our systems and controls
We maintain, where necessary, records of transactions that meet the needs of law enforcement investigations tackling money laundering and terrorist financing
We provide initial and ongoing training for all relevant employees
We support the nominated officer with resources and authority to operate objectively and independently
4. Risk Management
We have a policy and procedures in relation to risk assessment and management, as required under the Money Laundering Regulations 2007 (the Regulations). This risk-based approach involves a number of discrete steps in assessing the most proportionate way to manage and mitigate the money laundering and terrorist financing risks we face:
Identify the money laundering and terrorist financing risks that are relevant to us
Design and implement policies and procedures to manage and mitigate these assessed risks
Monitor and improve the effective operation of these controls
Record what has been done, and why
This risk-based approach focuses the effort where it is most needed and will have most impact. It has the full commitment and support of our senior management, and the active co-operation of all employees. We have conducted an assessment of our business risk exposure to money laundering, which considers the threat, and its impact.
5. Suspicious Activity
Suspicious Activity in this case is being referred to as suspicious transactions, extreme player profiles, when deposits are not matching up amongst other elements. Other concrete examples of how we identify players who require our team to undertake a risk monitoring approach of our customers and when to specifically carry out enhanced due diligence checks on the Player Profiles can be further required:
Passport or ID card.
Utility bill.
Bank statement.
Other proof of identity.
The Enhanced Due Diligence Checks are subject to players' profile and the amount of Risk they pose to us. Only when we determine some of the above points or a combination of a few will we flag the customer/customers in question and conduct risk monitoring. This will include checks of where the customer works, value of house, where the customer lives and checks to see whether the value of the house is logical compared to the customer's spending.
5.1 Suspicious Activity Reports (SARs)
Within that framework, Suspicious Activity Reports (SARs) are an imposed requirement. The Merchant ensures that any employee reports to the Risk Team where they have grounds for knowledge or suspicion that a person or customer is engaged in ML or terrorist financing. Any employee failing to so do is open to criminal prosecution.
Escalations of SARs should be done in a confidential, discreet manner, in a handwritten form and not via email so as to ensure maximum anonymity.
An employee must not, under any circumstances, disclose or discuss any AML concern with the person or persons subject to an investigation, or any other person for that matter. Disclosure (also known as "tipping off") is strictly prohibited and carries with it very serious legal penalties.
Furthermore, and in order to keep ourselves protected as much as possible, no remark should ever be left on an account that would give any indication that ML is suspected, a player being entitled, at any point in time, to request the full notes/remarks on their account.
5.2 Working Procedure
Merchant reviews players spend and game play to check for suspicious activity. Before any withdrawal is processed the following procedures are carried out:
The customer's deposit history is reviewed to confirm that no suspicious payments have been made to the customer's account. The frequency of deposits and the sum of deposits are reviewed to ensure they are within normal range for the customer based on his depositing history and the general depositing range throughout our network.
The customer's turnover is reviewed to ensure that they have played in the casino and are not using Merchant as a method to move money.
When possible, funds must always be refunded back to the original payment method used by the player to make a deposit.
5.3 Withdrawal Procedure
When reviewing a customer's account prior to withdrawal the agent must answer the following questions in the AML segment in the Risk Entry:
Did the player wager?
Does the payment Method belong to the player and has the player used it to deposit?
Are the customer's transactions and bets in line with expectations for the player?
5.4 Escalation Process
Following the AML policies in place and escalating any suspicious activity, as previously described, are crucial to the company as they protect it from financial losses and ensure that it remains compliant within the different jurisdictions which govern it.
Any activity which appears suspicious, even only slightly, has to be escalated. Not escalating a suspicion of money laundering can lead to criminal prosecution.
6. Sanctions Screening
The Merchant operates a zero-tolerance approach to dealing, directly or indirectly, with sanctioned individuals, entities, vessels or jurisdictions. All customers are screened against applicable sanctions and asset-freeze lists before a business relationship is established, before any withdrawal is processed, and on an ongoing basis thereafter.
6.1 Lists Screened
As a minimum, every customer is screened against the following consolidated sanctions lists, using an automated screening tool supplemented by manual review where a potential match arises:
European Union (EU) Consolidated List of Persons, Groups and Entities Subject to Financial Sanctions
United Kingdom (UK) OFSI Consolidated List of Financial Sanctions Targets
Australia Department of Foreign Affairs and Trade (DFAT) Consolidated List
United Nations (UN) Security Council Consolidated Sanctions List
United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) List and other OFAC sanctions programs
This list of screened sources is reviewed at least annually, or sooner where a relevant regulatory or licensing requirement changes, and additional lists may be screened where required by a jurisdiction in which the Merchant operates.
6.2 When Screening Is Performed
At onboarding, before a customer account is activated for real-money play
Before any withdrawal request is approved
On an ongoing basis against updated list versions, at a frequency set by the Compliance/Risk function (list providers typically update daily to weekly)
Immediately upon a change to a customer's identifying details (name, date of birth, nationality, address)
On an ad hoc basis where a new sanctions designation is announced that may affect an existing customer
6.3 Handling a Potential Match
Where the screening tool returns a potential match, the following procedure applies:
The customer account is immediately suspended from further deposits, withdrawals and gameplay pending review.
The Compliance function (or MLRO) manually reviews the match to confirm whether it is a true match or a false positive, using available identifying information (full name, date of birth, nationality, address, document numbers).
If the match is confirmed or cannot be reasonably discounted, the MLRO is notified immediately, funds associated with the account are frozen, and no funds are returned to the customer without confirmation that this would not breach applicable sanctions law.
The MLRO determines whether a report to the relevant sanctions authority (for example OFSI, OFAC or the equivalent competent authority) and/or a Suspicious Activity Report is required, and makes such report as required by law.
If the match is discounted as a false positive, the basis for that decision is documented and retained on the customer's file.
No employee may disclose to the customer that a sanctions check, freeze, or report has taken place ('tipping off').
6.4 Prohibited Jurisdictions
In addition to individual and entity screening, the Merchant does not knowingly provide services to customers located in, or making payments through, jurisdictions subject to comprehensive UN, EU, UK, Australian or OFAC sanctions programs, or jurisdictions identified in Section 9 (High Risk Jurisdictions) of this policy.
7. Politically Exposed Persons (PEPs)
7.1 Definition
A Politically Exposed Person (PEP) is an individual who is, or has been within the preceding 12 months (or such longer period as risk assessment requires), entrusted with a prominent public function. This includes, without limitation, heads of state or government, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, and important political party officials. The definition also extends to:
Family members of a PEP, including spouse/partner, children and their spouses/partners, and parents
Known close associates of a PEP, including any individual known to have joint beneficial ownership of a legal entity or arrangement, or any other close business relationship, with a PEP
7.2 Identification
All customers are screened against PEP databases and watchlists at onboarding and on an ongoing basis, using the same screening process described in Section 6. Where PEP status is identified or suspected, the customer is treated as high risk for the purposes of this policy.
7.3 Enhanced Due Diligence for PEPs
Where a customer is identified as a PEP, family member of a PEP, or close associate of a PEP, the following Enhanced Due Diligence (EDD) measures apply before the business relationship is entered into or continued:
Senior management (or the MLRO) approval is obtained before establishing or continuing the business relationship
Adequate measures are taken to establish the source of wealth and source of funds involved in the business relationship and transactions
Enhanced ongoing monitoring of the business relationship is conducted, at a greater frequency and depth than for standard customers
Additional identity, residence, and (where relevant) professional/public role verification is obtained
7.4 Ongoing Monitoring and Cessation of PEP Status
PEP status is reviewed on an ongoing basis, including at each periodic KYC refresh. Where an individual ceases to hold a prominent public function, EDD measures continue to apply for a risk-based period thereafter, having regard to the individual's ongoing risk profile, level of influence they may still exert, and the seniority of the position previously held.
7.5 Refusal and Escalation
Where source of wealth or source of funds cannot be satisfactorily established for a PEP, or where senior management/MLRO approval is not given, the Merchant will decline to open, or will suspend or terminate, the business relationship. Any grounds for knowledge or suspicion of money laundering or terrorist financing arising from a PEP relationship are escalated in accordance with Section 5.1 (SARs) of this policy.
8. Employees
8.1 Senior Management
Senior management is fully committed to and responsible for the implementation of this policy. Senior management is made aware of their individual personal liability for consenting to, or conniving in, the commission of offences under the Regulations, or where such offence is attributable to any neglect on his part.
8.2 MLRO
A designated Money Laundering Reporting Officer (MLRO) takes responsibility for SARs in respect of the prevention and detection of money laundering, counter terrorism financing and our obligations under the Proceeds of Crime Act 2000. The nominated MLRO has responsibility for:
making reports to senior management on anti-money laundering (AML) and countering terrorist financing (CTF) activity, including sanctions and PEP matters;
receiving disclosures from employees under Part 7 of the Proceeds of Crime Act 2002 (POCA) and Part III of the Terrorism Act 2000 (the Terrorism Act);
approving or declining high-risk relationships, including PEP relationships and confirmed sanctions matches; and
and if appropriate, making such external reports.
The MLRO has the authority to act independently in carrying out their responsibilities, and has access to sufficient resources to carry out their duties.
8.3 Staff Training
All staff will receive training on their obligations in respect of money laundering reporting and are aware of the procedures in place for escalation of any suspected incidents to the MLRO. As part of this process, staff are made aware that personal disregard for the legal requirements, for example, turning a blind eye to a customer spending criminal proceeds, may result in criminal or regulatory action.
Relevant employees receive training on how to follow house policies and procedures for:
Client due diligence (CDD), including enhanced requirements for high risk clients, which includes PEPs;
sanctions screening procedures and how to escalate a potential match;
reporting suspicious activity to the nominated officer where necessary, seeking appropriate consent to allow participation in gaming and to conduct gaming and other business transactions
9. High Risk Jurisdictions
High risk countries are those countries identified as such by publications issued from time to time by the Financial Action Task Force; or additionally those so identified by the Gambling Commission. Clients registered in High Risk Countries are always subject to EDD.
Countries currently on the FATF list are:
Players from the FATF list of jurisdictions seen to threaten the international financial system from on-going and substantial money-laundering or terrorist financing activities, as identified on FATF publications, will be refused.
10. Record Keeping
We ensure that there is an audit trail to assist in any financial investigation by a law enforcement body. Our record keeping policy and procedure covers records in the following areas:
Details of how compliance has been monitored by the nominated officer
Delegation of AML/CTF tasks by the nominated officer
Nominated officer reports to senior management
Information not acted upon by the nominated officer, with reasoning why no further action was taken
Customer identification and verification information
Supporting records in respect of business relationships or occasional transactions
Sanctions and PEP screening results, including the rationale for discounting any potential match
Employee training records
Internal and external SARs
Contact between the nominated officer and law enforcement or the NCA, including records connected to appropriate consent
11. Offences
All employees are made aware of their risk of committing the following related offences:
POCA and the Terrorism Act create offences of failing to report suspicious activity
Where an employee fails to comply with the obligations to make disclosures to a nominated officer, or the nominated officer to NCA, as soon as practicable after the information giving rise to the knowledge or suspicion comes to that person, they are open to criminal prosecution
They may also commit an offence under POCA or the Terrorism Act if they disclose information that an SAR has been submitted that is likely to prejudice any investigation, or disclose information that an investigation into allegations that an offence under POCA or the Terrorism Act has been committed, that is likely to prejudice the investigation
They also commit an offence if they know or suspect that an appropriate officer is acting (or proposing to act) in connection with a relevant investigation which is being or is about to be conducted, and they falsify, conceal, destroy or dispose of documents which are relevant to the investigation
Breach of applicable sanctions law (including dealing with a designated person or entity) is a criminal offence in most of the jurisdictions whose sanctions lists are screened under Section 6
12. Vetting Procedures for New Employees
The company undertakes a number of vetting procedures when staff are employed. We will ensure the employee is not a minor through proper identification checks and we will verify the identification and credentials of the employee through at least two independent references. We will also look to verify any further personal information or background information.
13. Protecting Our Equipment from Internal Crime and Criminal Misuse
The company is very aware that a key way to combat fraud is to first identify where the company's most valuable assets are. Processes and controls have been built into the routine business of the company to minimize the chances of any of the key assets being misused.
Our server equipment are located at Amazon Europe who have in place necessary policies around protection of equipment, for example, a visitors management procedure, fire alarms, shredding of confidential documents, locked cabinets, testing, a security team etc. Merchant also implements such policies at our offices.
14. Compliance and Risk Committee
We intend to establish this to review executive risk. Both the MLRO and Compliance Officer will be members as will another non-executive director. These will meet no less than quarterly or as required.
15. Ensuring the Companies We Deal With Are Trustworthy and Reputable
Merchant promotes strong principles of business and professional ethics at every level. When selecting suppliers, there are a number of criteria we consider:
Financial strength (for long term sustainability);
Legal and regulatory compliance;
Commitment to a wider corporate responsibility program;
Desire and ability to deliver quality and value.
All new suppliers must go through a rigorous approvals process where all information put forward by them is verified.
This information is then assessed internally to consider the risks associated with the supplier; taking into account all of the above criteria. If rejected, the supplier will be informed. Merchant ensures that all organisations we contract with understand the compliance obligations under the relevant player jurisdictions.
16. Internal Record Keeping
The below key principles: know your customer, internal record keeping and reporting, ensure our compliance with laws and regulations.
Records on all customer transactions - regardless of their relation to payments or plays - will be kept for at least 6 years after the transaction.
Records on customer details - regardless of their value state or open/blocked status - will be kept for at least 6 years after the relationship with the customer was terminated.
Records on money laundering investigations and suspicious activity reports will be kept for 6 years after the investigation was completed.
Sanctions and PEP screening records will be kept for at least 6 years after the relationship with the customer was terminated.
17. Prevention of Collusion and Data Protection Compliance
The Merchant Terms and Conditions make clear that cheating will not be tolerated and that customer accounts will be closed if cheating occurs.
In terms of data protection, all data related to user payment accounts is stored, encrypted, and managed by Payment IQ, and Merchant employees have no access to user payment information. All Customer Information in the organization will be protected through a strict Information Security policy that all employees and suppliers will adhere to, that will include System Access and Authentication Control, Password Policy, Malware Protection measures, Intrusion Prevention policy, Encryption Policy, and strict Network Control and Management.
18. Approval and Sign-Off
This Anti-Money Laundering Policy has been reviewed and approved by the following individuals on behalf of Jackpot Junction Limited:
Director
Name: Emil Georgiev
This policy is subject to review at least annually, or sooner where required by a material change in law, regulation, or the Merchant's business or risk profile.