Anti Money Laundering

AML Procedures

Introduction

The Company has put in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity. The Company is therefore obliged to follow the provisions contained in the international legal framework and the Prevention of Money Laundering rules, by using as model, the rules prescribed in Directives 2005/60/CE and 2006/70/CE to Prevent Money Laundering and Funding of Terrorism.

 

Objective

 

The Company is fully committed to prevent money laundering and combat the financing of terrorism to minimize and manage risks such as the risks to its reputational risk, legal risk, and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

The Company will endeavor to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, always, the organization and its operations and safeguards its reputation from the threat of money laundering, the funding of terrorist and other criminal activities.

 

Obligations

 

To adhere to the requirements of the Prevention of Money Laundering Act, the regulations and any guidance notes The Company has implemented:

  • One of its senior officers as the designated Money Laundering Reporting Officer (MLRO) whose responsibilities will include the duties required by the law regulations and guidance notes.
  • Take reasonable steps to establish the identity of any person for whom it is proposed to provide its service.
  • Keep at all times a secure online list of all registered Players.
  • Retain identification and transactional documentation as defined in the laws regulations notes.
  • Provide initial and ongoing training to all relevant staff and procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions.
  • Ensure that this policy is developed and maintained in line with evolving statutory and regulatory obligation and advice from the relevant authorities.
  • Examine with special attention, and to the extent possible, the background and purpose of any complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.
  • Report any suspicion or knowledge of money laundering of terrorism financing to the Board and, if need to report these abuses to the Financial Minister of the Board for the collection, collation, processing, analysis and dissemination of information with a view to prevent money laundering and combat the funding of terrorism.
  • Cooperate with all relevant administrative, enforcement and judicial authorities in their endeavor to prevent and detect criminal activity.

The Company will not:

  • Accept to open anonymous Accounts or Accounts in fictitious names such that the true beneficial owner is not known.
  • Accept cash from Players. Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other method approved by the company Board.
  • Register a Player who is under eighteen (18) years of age.
  • Only register a single account in the name of a person: multi-account practices are strictly prohibited.
  • Transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.
  • Accept a wager unless a User Account has been established in the name of the Player and there are adequate funds in the Account to cover the amount of the wager.
  • Not accept a wager unless the funds necessary to cover the amount of the wager are provided in an approved way.
  • Accept Players residing or playing from non-reputable jurisdictions.
  • Make a payment in excess of KES 250,000 out of a User Account to a Player until the Player's identity, age and place of residence have been verified.
  • If no transaction has been recorded on a User Account for thirty months, close the User Account and remit the balance in that account to the Player.
  • Where it seems necessary, verify creditworthiness of the Player with third parties who previously provided any information on the Player.
  • If it becomes aware that a person has provided false information when providing due diligence documents, not register such person. Where that person has already been registered, The Company will immediately cancel that person's registration as a Player with the company.