AML Policy

Policy approval

XYZ Entertainment B.V. (Curaçao) (the ‘Company’) (‘We’) is a company registered and incorporated in Curacao with Company registration: 157447.

Gaming License Number: 8048/JAZ

The company is further approved to accept and transact with customers in crypto (digital or virtual) currencies.

We are committed to preventing our systems from being used for Money Laundering, Terrorist Financing or other crime. This includes actioning the following steps:

General provisions

We are fully committed to applying measures to prevent Money Laundering and Combatting Terrorism Financing. We are also committed to our social duty in preventing our systems from being used as a tool for crime.

We will endeavour to stay updated with developments in prevention measures in order to protect the organisation, its operations and reputation.

Our policies and procedures were built and continue to be updated to observe the laws relevant to our operations.

Laws and regulations

The Curaçao Gaming Control Board is the designated supervisory Authority for our service.

We are required to comply with all applicable laws and regulations within the jurisdiction of Curaçao, including National Ordinances covering the criminal code, identification for services, identification when rendering services, and the reporting of unusual transactions.

We are required as a service provider of online games of chance to have in place adequate practices and procedures to prevent our systems from activity facilitating money laundering and the funding of terrorist and criminal activities.

Customer due diligence

We will apply appropriate customer due diligence measures required by law, including utilizing identifiers.

At any time a customer’s risk profile changes based upon any number of ‘red flags’, we will conduct enhanced due diligence, including verification based on personal documents, and publicly held data, privilege information from other operators and sources, financial or corporate data, and third-party data providers.

We have a duty to monitor all customer relationships in accordance with industry best practice, international recommendations and guidelines.

Any suspicious transactions or circumstances potentially related to Money Laundering and Terrorist Financing will be reported to the relevant law enforcement authority.

Where due diligence checks cannot be completed, we will suspend the business relationship until such time as all checks have been satisfactorily completed.

Cryptocurrency transactions

The company is entitled to perform additional background and security checks for the customers wishing to deposit or withdraw using cryptocurrencies. In case of suspicion, the company has the right to suspend the customer account and request additional Due Diligence documentation from the customer.

If we are not able to be assured of either the identity of the customer or the source of funding, the matter can be referred to the management board and service provider for review and final decision.

If the decision is to terminate the relationship any retained customer funds will be held in a seized funds account and declared as part of any suspicious activity report made to law enforcement.

Reporting suspicions

As a Curacao eGaming IP licensee, we are obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance and as a registered body of the Department of the Financial Intelligence Unit (FIU).

A customer being identified as being on a sanctions list, linked to Money Laundering, the Financing of Terrorism, or other criminal activity, may warrant the submission of a formal suspicious activity report to law enforcement. Monitoring for Suspicious Behaviors Criteria for KYC Request: Activities that may prompt a KYC request include, but are not limited to, patterns of depositing and withdrawing funds without participating in any gaming activities. Such behaviors are closely monitored and may be indicative of potential fraud or money laundering.

KYC Request Due to Suspicious Behavior: Should your account exhibit such suspicious activity, you will be notified and requested to complete the KYC verification process. This is a necessary step to verify the identity of the account holder and the legitimacy of the transactions.

Consequences of Non-Compliance Account Deletion for Failure to Complete KYC: It is important to respond promptly to a KYC request. Accounts that fail to complete the KYC process within 30 days of the request being made will face permanent deletion. This policy is enforced to ensure the safety and security of all users and to comply with regulatory standards.

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