AML Policy

AML Policy Against Money Laundering - velvetcas.com

For the deposit and withdrawal of cash.

Introduction

The purpose of the AML policy at velvetcas.com is to ensure maximum security for all our users and clients, which is achieved through a two-step account verification process to confirm the identity of our clients. The aim is to ensure that the data of the registered individual is accurate and that the methods used for depositing funds are not stolen or used by third parties, creating a common foundation for combating money laundering. We also consider that depending on citizenship, origin, payment method, and withdrawal of funds, different security measures need to be implemented.

velvetcas.com also applies reasonable measures to control and limit the risks of money laundering, including allocating appropriate resources.

velvetcas.com strives to comply with high standards of anti-money laundering (AML) in accordance with EU recommendations and requires management and staff to adhere to these standards to prevent the use of our services for money laundering purposes.

AML Program

The AML program at velvetcas.com is designed in accordance with:

• EU: “Directive 2015/849 of the European Parliament and Council of May 20, 2015, on preventing the use of the financial system for money laundering.”
• EU: “Regulation 2015/847 on information accompanying transfers of funds.”
• EU: Various regulations establishing sanctions or restrictive measures against individuals and embargoes on certain goods and technologies, including all dual-use goods.
• Belgium: “Law of September 18, 2017, on preventing money laundering and limiting the use of cash.”

Definition of Money Laundering

Money laundering is understood as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or participation in such activity, with the aim of concealing or disguising the illegal origin of the property or assisting any person involved in such activity to evade legal consequences of their actions;
• The concealment or disguise of the true nature, source, location, disposition, movement, rights regarding, or ownership of property, knowing that such property is derived from criminal activity or participation in such activity;
• The acquisition, ownership, or use of property, knowing at the time of receipt that such property is derived from criminal activity or assisting such activity;
• Participation, assistance, attempts to commit, as well as aiding, abetting, counseling, and procuring the commission of any of the above actions.

Money laundering is considered such even if the actions that led to the property being laundered were committed in the territory of another member state or third country.

AML Organization for velvetcas.com

In accordance with AML legislation, velvetcas.com has appointed a "senior level" for preventing money laundering: overall management is responsible.

Additionally, an AML Compliance Officer (AMLCO) has been appointed, who is responsible for ensuring compliance with AML policies and procedures within the system. The AMLCO is directly accountable to senior management.

Changes to the AML Policy and Implementation Requirements

Any major changes to the AML policy of velvetcas.com are subject to approval by senior management and the AML Compliance Officer.

Two-Step Verification

First Step of Verification

The first step of verification must be completed by every user and client for withdrawing funds. Regardless of the chosen payment method, payment amount, withdrawal amount, withdrawal method, and citizenship of the user/client, the first step of verification must be completed first. The first step of verification consists of a document that must be filled out by the user/client themselves. The following information must be provided: first name, last name, date of birth, country of usual residence, gender, and full address.

Second Step of Verification

The second step of verification is mandatory for each user who deposits or withdraws an amount exceeding $10,000. Until the second step of verification is completed, the withdrawal of funds, tips, or deposits will be suspended. The second step of verification directs the user or client to a subpage where they must provide their identification. The user/client must photograph their identification next to a piece of paper with a randomly generated six-digit number. Only official identification can be used for identity verification, and the list of acceptable IDs may vary depending on the country. Additionally, the user/client may be asked for the source of income. An electronic check is also conducted to ensure that the information provided in the first step of verification matches the document provided and the name on the identification. If the electronic check fails or is impossible, the user/client is required to provide proof of their current residence. A government-issued registration certificate or similar document is required.

Customer Identification and Verification (KYC)

Formal identification of clients when establishing commercial relationships is an important element for both money laundering legislation and KYC policy. This identification is based on the following principles:

• A copy of a passport, identification card, or driver's license with a handwritten note containing six randomly generated digits. A second photo of the user/client's face is also required.
• The user/client may redact any information except for the date of birth, citizenship, gender, first name, last name, and photograph to protect their privacy.

All four corners of the identification must be visible in one image, and all details except those mentioned above must be clearly readable. If necessary, we may request all details. An employee may conduct additional checks if needed.

Address Verification

Address verification is conducted through two different electronic checks. If the electronic check fails, the user/client may provide manual confirmation: a utility bill issued within the last 3 months, or an official document confirming the place of residence. All four corners of the document must be visible, and the text must be clear.

Source of Funds

If a player deposits more than €5,000, a source of income (SOW) investigation process is conducted. Examples of sources of income include business ownership, employment, inheritance, investments, and family. The account will be frozen until the source of funds is verified.

Risk Management

To manage various risks, velvetcas.com classifies each country into three risk regions:

• Region 1: Low Risk
• Region 2: Medium Risk
• Region 3: High Risk – blocked

The list of high-risk regions is updated regularly.

Additional Measures

Artificial intelligence under the supervision of the AML officer monitors unusual behavior, and specialists conduct additional checks of transactions, sources of funds, and user activity. Withdrawals must be made using the same method as the deposit.

Continuous Transaction Monitoring

1. First Line of Defense: cooperation with trusted payment service providers with effective AML policies.
2. Second Line of Defense: conducting due diligence on all client transactions, including an adapted three-step verification process.
3. Third Line of Defense: manual checks of all suspicious and higher-risk users to prevent money laundering.

Reporting Suspicious Transactions

All atypical transactions are analyzed by the AML team. Based on the analysis, a decision is made on whether to send a report to the Financial Intelligence Unit (FIU) and/or terminate business relationships with the client.

Procedures and Data Storage

All AML rules, including KYC, are documented in operational manuals. Identification and transaction data are stored for at least ten years after the termination of business relationships, in encrypted form.

Training and Audit

Employees undergo mandatory AML training and academic sessions. Internal audits conduct regular AML checks.

Data Security

All user/client data is securely protected and not shared with third parties without legal grounds. velvetcas.com complies with the Data Protection Directive 95/46/EC.