AML POLICY
1. Experience
1.1. Goodwin NV (hereinafter referred to as the “Company”) has extensive experience in protecting gaming operations against criminal exploitation and in implementing comprehensive processes to combat fraud and money laundering, including procedures and extensive training programs for staff.
1.2. Future training programs will build on knowledge of Proceeds often Crime Act as well as the indicators of money laundering commonly identified in gaming environments, particularly in transactions where cards are not physically used ( Card Not Present environments).
1.3. The company’s director has full knowledge of all aspects of Proceeds often Crime Act and his areas of responsibility. The Director is well-suited to disseminate knowledge about anti-money laundering measures and requirements, as he has previously secured both online and land-based gaming operations in this field.
2. Money laundering and transaction fraud
2.1. Gambling environments are often targets for money launderers. Fast transactions and the availability of a wide range of payment methods make gambling companies particularly vulnerable.
2.2. Therefore, many of the initial business and procedural decisions are either directly aimed at countering this threat, or protection is enhanced as a natural consequence of the company’s overall strategy.
2.3. All staff receive training in recognizing indicators of money laundering, such as (but not limited to):
- 2.3.1. unusual playing patterns,
- 2.3.2. suspicious deposit and withdrawal patterns (size and frequency),
- 2.3.3. reliability of card details,
- 2.3.4. customer verification problems and identity theft,
- 2.3.5. connections between accounts or multiple accounts per customer.
2.4. All suspected attempts at money laundering must be reported to the MLRO (Money Laundering Reporting Officer). However, the suspicion may not be conveyed to the customer, and further action may only be taken after approval. The MLRO is responsible for reporting suspicious activity and keeping relevant records updated.
2.5. The company will implement a complete Know Your Customer (KYC) policy. This not only prevents money laundering, but also other types of fraud. Customers are already informed upon registration and on the website that the company uses online verification tools, and if these are not sufficient, identity and address documents will be requested.
2.6. Additional safeguards include withdrawal limits: for example, requiring checks and director approval before card withdrawals and bank transfers over $3,000 are processed. A maximum of three withdrawals per day are permitted, with a total maximum limit of $9,000 per day.
2.7. Industry standard that always leads to Enhanced Due Diligence (additional proof of identity and address) is withdrawals exceeding $3,000 in 24 hours, or $9,000 in a 90-day period.
2.8. The business will not handle cash, which reduces the risks associated with counterfeit money.
2.9. Systems will record all transactions on each account. These histories are regularly reviewed against fraud patterns and social responsibility indicators. Where anomalous gambling and winning patterns are detected, cross-references are made with call histories to ensure that staff are not colluding inappropriately with customers.
2.10. The Company will maintain a register of customers identified as high risk or politically exposed persons (PEPs). These accounts will be reviewed more frequently and thoroughly.
2.11. In general, in the event of illegal or inappropriate behavior by personnel, the company will follow the disciplinary measures specified in employment contracts and labor laws. This includes investigations and, to a greater extent, measures such as suspension in the event of suspected transaction fraud.
3. Security and monitoring
3.1. It is essential to have adequate monitoring procedures in place in a gaming operation – for premises, equipment, personnel, communications and transactions. The company will implement a range of measures to ensure security in all of these areas.
3.2. The company has installed call recording technology, which provides several advantages:
- 3.2.1. personnel training,
- 3.2.2. ensuring correct game time, stakes and transaction data,
- 3.2.3. protection of customer and brand reputation,
- 3.2.4. robust and frequent monitoring to discourage collusion between staff and customers.
3.3. The protection of data and the security of software and hardware are crucial in an environment where transactions take place without physical meetings. The company will therefore follow the policy “Encrypt everything that can be encrypted” . Access to shared folders will be strictly limited, monitored and, where necessary, password-protected . Secure storage and backup procedures are used to protect customer data against unauthorized access and prevent data loss.
4. Responsible relationships with customers and partners
4.1. The Company will publish its General Terms and Conditions as well as KYC and AML policies on the website. These will contain specific references to fraud, prior knowledge of game results, match fixing and suspicious events. The policy describes what measures the Company can take in case of suspicion of cheating and the extent to which the Company cooperates with regulatory authorities and sports federations. This enables transparent communication with customers.
4.2. The Director stresses, however, that if serious crime is suspected or identified, it is important that neither the customer nor the suspects are informed ( ‘ tipping off’ is prohibited). Alternative methods may then be required. Staff receive specific training and clear procedures for escalation.
4.3. The company will take all necessary measures to ensure the seriousness of cooperation with other businesses. This includes standardized due diligence , often with confidentiality agreements. The company will require information on ownership, management structure, registration certificate, address and contact information as a basic requirement. The results are documented in templates and archived.