AML & CTF Policy | Star Wagibet Casino

Anti-Money Laundering and Counter-Terrorism Financing Policy

Last Updated: December 2024

Star Wagibet Casino is committed to preventing money laundering and terrorism financing. This policy outlines our compliance measures and procedures to detect, prevent, and report suspicious activities.

1. Policy Commitment

  • Zero tolerance for money laundering and terrorism financing
  • Full compliance with applicable AML/CTF laws and regulations
  • Cooperation with law enforcement and regulatory authorities
  • Regular review and update of policies and procedures
  • Staff training on AML/CTF compliance requirements

2. Customer Due Diligence (CDD)

Identity Verification Government-issued ID verification for all customers
Address Confirmation Proof of address through utility bills or bank statements
Enhanced Due Diligence Additional checks for high-risk customers and large transactions
Ongoing Monitoring Continuous monitoring of customer activity and transactions

3. Know Your Customer (KYC) Requirements

  1. Account Registration: Collect and verify customer identity information
  2. Source of Funds: Verify the legitimate source of customer funds
  3. Risk Assessment: Evaluate customer risk based on various factors
  4. Ongoing Reviews: Regular review of customer information and activity
  5. Record Keeping: Maintain comprehensive records for required periods

4. Transaction Monitoring

  • Automated Systems: Real-time monitoring of all transactions
  • Suspicious Patterns: Detection of unusual or suspicious activity
  • Threshold Monitoring: Tracking transactions above certain amounts
  • Structured Transactions: Identification of potential structuring attempts
  • Cross-Border Movements: Enhanced monitoring of international transfers

5. Prohibited Activities

Money Laundering Converting illegally obtained funds to appear legitimate
Terrorism Financing Providing funds or financial services to support terrorism
Structuring Breaking transactions into smaller amounts to avoid reporting
Shell Accounts Using fake identities or nominee accounts
Smurfing Using multiple accounts to disguise transaction origins

6. Risk Assessment Factors

  • Geographic Risk: Customer location and high-risk jurisdictions
  • Customer Type: Individual vs. corporate customers, PEPs
  • Transaction Patterns: Frequency, amounts, and timing of transactions
  • Product Risk: Different games and services pose varying risks
  • Delivery Channels: Online vs. land-based transaction channels

7. Suspicious Activity Indicators

  1. Unusual Deposits: Large cash deposits from unknown sources
  2. Rapid Withdrawals: Immediate withdrawal of deposited funds
  3. Minimal Gaming: Depositing funds with little or no gaming activity
  4. Multiple Accounts: Attempts to create multiple accounts
  5. Inconsistent Information: Providing false or inconsistent details
  6. Unusual Payment Methods: Using uncommon or high-risk payment methods

8. Reporting Procedures

Internal Reporting Staff must report suspicious activities to compliance team
Regulatory Reporting Submit reports to relevant financial intelligence units
Timeframes Reports submitted within required regulatory timeframes
Confidentiality Strict confidentiality maintained for all reports

9. Record Keeping

  • Customer Records: Identity and verification documents
  • Transaction Records: All deposits, withdrawals, and gaming activity
  • Correspondence: Communications with customers and authorities
  • Compliance Records: AML/CTF policies, procedures, and training
  • Retention Period: Minimum 7 years or as required by law

10. Staff Training and Awareness

  • Regular AML/CTF training for all staff members
  • Updates on new regulations and compliance requirements
  • Recognition of suspicious activity indicators
  • Proper reporting procedures and escalation protocols
  • Annual certification and competency testing

11. Sanctions and Watchlist Screening

  1. Global Sanctions Lists: Screening against international sanctions
  2. PEP Lists: Identification of Politically Exposed Persons
  3. Real-time Screening: Ongoing monitoring of watchlist updates
  4. Match Resolution: Investigation and resolution of potential matches
  5. Blocked Transactions: Immediate freezing of sanctioned accounts

12. Third-Party Risk Management

  • Due diligence on payment processors and service providers
  • Regular review of third-party compliance standards
  • Contractual obligations for AML/CTF compliance
  • Monitoring of third-party relationships and transactions

13. Compliance Monitoring and Review

Internal Audits Regular assessment of AML/CTF compliance effectiveness
External Reviews Independent evaluation by qualified professionals
Regulatory Updates Monitoring changes in laws and regulations
Policy Updates Regular review and update of policies and procedures

14. Enforcement and Penalties

Violations of this AML/CTF policy may result in:

  • Account suspension or closure
  • Confiscation of funds involved in suspicious activities
  • Reporting to law enforcement authorities
  • Legal action and prosecution
  • Regulatory sanctions and penalties

15. Contact Information

For AML/CTF compliance matters, contact:

Compliance Officer:
Innovista Limitada
Province 06 Puntarenas, Canton 11 Garabito, Jaco – Pastor Diaz Ave, 61101, Costa Rica