Anti Money Laundering Policy of Pin Up Casino Bangladesh

1. Introduction

1.1 Money Laundering

Money Laundering, abbreviated as ML, is the act of disguising the source of money obtained from illegal activities like narcotrafficking or terrorism. Those who commit ML manipulate the look of these funds, change their form, or move them to areas that are less likely to attract attention.

1.2 Anti-Money Laundering

The term Anti-money laundering (AML) refers to the legal frameworks that require financial institutions and other regulated entities to prevent, detect, and report activities indicative of money laundering. An effective AML strategy requires a jurisdiction:

• Declaring ML as a criminal offense
• Empowering regulators and law enforcement agencies with the authority to investigate.
• Financial institutions are required to identify their clients, implement risk-based controls, keep records, and report any unusual activities.
• To enable information sharing with other regions as needed

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2. Regulation

Employees in the remote gaming industry are required to submit reports on any information they come across while performing their professional duties:

• Upon actual knowledge
• Upon suspicion
• If there are reasonable grounds to suspect money laundering or financing of terrorism activities, such as unlawful expenditures

The purpose of these reporting responsibilities is to show that a detailed risk assessment took place before forming client relationships and that ongoing customer due diligence is upheld to ensure transactions correspond with the related risk levels.

2.1 Specific Regulations

The Merchant is dedicated to incorporating compliance into all aspects of our operations and holds authorization from the licensed Curacao Gaming License for online gambling.

3. AML Policy and Crime & Disorder

We have designed our AML policy based on principles that guarantee compliance with legal standards and regulatory requirements:

• Creating and sustaining appropriate controls customized for our businesses
• Yearly evaluation of AML risks in our organization
• Active involvement of senior management in a focused and thorough way
• Consistent assessment of our control systems
• Equipping our designated officers with sufficient resources and the authority they need to operate independently

4. Risk Management

Our protocol includes a methodology for risk management and assessment as outlined by the Money Laundering Regulations 2007. This comprises:

• Identifying relevant risks associated with ML and terrorist financing
• Developing and executing strategies to reduce these risks
• Continuous oversight and improvement of these strategies
• A record of the actions undertaken along with the reasoning behind them

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5. Suspicious Activity

Often, identifying suspicious activities requires analyzing unusual transaction patterns or extreme player profiles, along with other indicators.

5.1 Reports of Suspicious Activity (SARs)

Any concerns about ML or terrorist financing must be reported to the Risk Team in a confidential manner to prevent legal consequences and ensure discretion.

5.2 Working Procedure

Before any withdrawals are processed, a detailed review of the customer's past transactions and gaming activities is carried out to identify any inconsistencies.

5.3 Withdrawal Procedure

Before approving any withdrawals, it is essential to conduct a detailed analysis of a customer's gameplay and transactional behavior to ensure compliance with AML regulations.

5.4 Escalation Process

Any indication of questionable activity should be elevated as per our strict AML policies to avert possible financial and legal consequences.

6. Employees

6.1 Senior Management

The commitment of our senior management to uphold and implement our AML policies is unequivocal.

6.2 Officer for Reporting Money Laundering (MLRO)

The MLRO we have appointed is responsible for managing all aspects concerning SARs and ensuring compliance with the Proceeds of Crime Act 2000 along with associated legislation.

6.3 Staff Training

All employees receive extensive training on AML obligations to cultivate a watchful and compliant workforce.

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7. Jurisdictions with High Risk

Transactions originating from countries on the FATF list face strict examination or are outright banned depending on the level of risk they present.

8. Record Keeping

We keep a detailed log of all activities related to AML to assist with any future investigations by law enforcement.

9. Offences

Employees receive training on the legal implications of failing to comply with AML regulations.

10. Procedures for Vetting New Employees

To ensure that all new hires align with our standards of integrity and compliance, we implement thorough vetting processes.

11. Safeguarding Our Equipment Against Internal Theft and Misuse

To safeguard our valuable assets from unauthorized access or misuse, we implement strict security measures.

12. Risk and Compliance Committee

To guarantee uniform compliance throughout our operations, a committee is formed to supervise risk management practices.

13. Guaranteeing That the Companies We Engage with Are Reliable and Well-Regarded

We collaborate exclusively with suppliers who fulfill our rigorous standards for financial stability, adherence to legal regulations, and ethical behavior.

14. The Duties We Have Under the Proceeds of Crime Act (POCA)

We strictly follow the guidelines set by the Proceeds of Crime Act 2002, making sure we comply with all applicable regulations.

15. Maintaining Internal Records

As part of our AML compliance efforts, we keep thorough records of every customer transaction and interaction.

16. Ensuring Data Protection Compliance and Preventing Collusion

Strong policies are established to safeguard customer information and prevent data breaches.