AML Policy

Anti Money Laundering and Terrorism Financing Prevention Policy
Version 1.3

1. The AML Policy

At Kirgo, your safety is our top priority. We’re committed to providing you with an exciting and secure gaming experience, valuing transparency. We adhere to global Anti-Money Laundering (AML) compliance standards to maintain the highest integrity in all our actions. 

In the following overview, we will provide you with all the details of our AML Policy.

1.1. AML Policy Overview
Our AML Policy, meticulously implemented by our dedicated team, is a safeguard that ensures your safety and maintains the integrity of our services.

This policy strictly adheres to Curacao’s anti-money laundering and terrorist financing laws, including the National Ordinance on identification when providing services and the National Ordinance on reporting unusual transactions. We also consider recommendations from significant organizations such as the Financial Action Task Force on Money Laundering and Terrorist Financing (FATF), the Caribbean Financial Action Task Force (CFTAF), and relevant documents.

The responsibility for overseeing and implementing measures to prevent AML and FATF, ensuring full compliance with required standards, lies with two pivotal entities: The Curacao Gaming Control Board and Cyberluck Curacao N.V.

1.2. Why It Matters To You
This policy is in place to protect your interests and ensure that our operations are fair, secure, and compliant. It applies when you establish a relationship with us or when we monitor your account activities.

1.3. Who Does It Apply To
When you sign up for an account on our website as a player at Kirgo, this policy will apply to you. We value your satisfaction and peace of mind and will refer to you as “You,” “Your,” “Customer,” or “Player” in this policy overview.

2. Operational Details

2.1. How We Operate
At Kirgo, we exclusively use virtual currencies called “Funds” for our services to provide you with an enjoyable and secure gaming experience.

We monitor your transactions and behavior to detect any unusual activity. Examples of such behavior may include unusual deposits and withdrawals into or from your Player Account, irregular betting patterns, misuse of bonuses or promotions, unfair practices, attempts to gain an unfair advantage, opening multiple accounts to exploit promotional offers, or engaging in fraudulent activities.

3. Risk Assessment

3.1. Understanding the Risks & Detecting Unusual Activity
It is important to recognize that our services may be exploited for money laundering and terrorist financing. Any unusual transaction that deviates from typical customer behavior will trigger our monitoring system. At Kirgo, we conduct regular, comprehensive reviews of complex or unusual transactions and activity patterns lacking a clear, legitimate purpose.

These procedures aim to ensure the proper use of our services for their intended purposes.

In cases where you provide the requested information, explanations, or documents, and it helps mitigate the risk, we will decide whether to continue or end a relationship with you.

3.2. Categorizing Customers
To better manage these potential risks, we categorize all our customers into groups based on their identity and certain risk characteristics. These categories are:

  • Low-Risk Customer
  • Medium Risk Customer
  • High-Risk Customer

3.3. Initial Customer Classification
Initially, all customers are categorized as Low-Risk Customers until we complete specific reviews and assessments on your Player Account.

3.4. Customer Onboarding Process
Our assessment of your category is based on several risk factors used to determine whether you fall into one of the three categories mentioned in point 3.2:

  • Adverse Media: This includes any negative news in the media related to you, like connections to illegal activities or financial crimes.
  • Politically Exposed Person (PEP): If you hold or have held prominent political positions, you fall into this category.
  • Sanctions Lists: If your name appears on any sanction list, it affects your risk classification.
  • High-Risk Geography: Customers in regions considered high-risk or closely monitored by financial authorities also come under scrutiny.

4. Enhanced Due Diligence

4.1. Enhanced Due Diligence (EDD)
If our risk-based assessment indicates that only one risk factor applies to you, making you a Medium-Risk Customer, we’ll perform Enhanced Due Diligence (EDD).

4.2. How We Protect You
During the Enhanced Due Diligence (EDD) process, we take specific measures to reduce the risk of AML or FATF:

  • We may request additional information, explanations, or documents from you.
  • Management approval is obtained before establishing the business relationship.
  • We gather information or documents regarding your source of funds (SOF) and wealth (SOW).
  • We collect any other relevant data or information to ensure your safety.

As we provide our services, we continuously monitor your account, conduct regular reviews to ensure the accuracy of your information, and promptly report any suspicious activities to the Governing Authorities.

4.3. Reliable Sources
We rely on publicly available information, tools, and trusted, independent sources to evaluate your risk. These sources include well-known websites like www.google.com, http://www.sanctionssearch.ofac.treas.gov, http://www.dilisense.com/, and other alternative websites or databases from service providers.

During our evaluation, we look for keywords like bribery, money laundering, fraud, and others to ensure a thorough check.

4.4. High-Risk Customers
If you are identified as a high-risk customer, you cannot establish a relationship with us in any regard.

4.5. Data Storage & Protection
We adhere strictly to data storage and compliance guidelines, meticulously documenting and securely storing all data collected during the risk evaluation and Enhanced Due Diligence (EDD) stages.

5. AML Compliance

5.1. Keeping Records Accurate
To maintain the accuracy of our records, we regularly update your data, documents, and information. These updates are done at least once every 24 months. However, if we performed Enhanced Due Diligence (EDD) during your onboarding, updates will be needed at least once every 12 months.

5.2.Establishing a Business Relationship
If no risk factors apply to you, we establish a business relationship, categorizing you as a Low-Risk Customer. This decision is recorded in our Register for establishing business relationships with Customers.

While we provide our services, we continue to monitor your activities, conduct periodic data reviews, and promptly report any unusual or suspicious activity to the Supervisory authority to maintain a secure environment for all our customers.

5.3. Recording Suspicious Activity
To combat money laundering and terrorist financing, we thoroughly document all suspicious or unusual transactions in writing. These records are securely stored for at least five years and are accessible to the relevant Curacao Governing Authorities.

5.4. Reporting to Senior Management
Whenever we detect and document an unusual or suspicious transaction, our Management is notified through an internal report using an approved method. This report includes all the relevant data related to any customer being reported.

5.5. External Reporting
After thoroughly evaluating the transaction’s nature, risks, and other relevant circumstances, and with Management’s authorization, we prepare an external report and promptly submit it to the Curacao Governing Authorities.

5.6. Transparency in Decision-Making
If Management decides not to authorize the inclusion and reporting of an unusual transaction, we keep detailed records to ensure transparency. These records contain all relevant documents related to the transaction and the reasons for non-authorization. Management signs these records, and we maintain them for internal purposes as outlined in our Policy.

5.7. Monitoring and Reporting Officer
We have appointed a Money Laundering Reporting Officer (MLRO) responsible for submitting a preformatted report quarterly to the designated authorities based on our risk analysis of AML compliance at Kirgo.

5.8. Compliance in Reporting
Our Executive Director is responsible for drafting the AML report and ensuring its timely presentation and approval by the MLRO before submission to the Curacao Governing Authorities.

5.9. Comprehensive Reporting
The MLRO is crucial in ensuring that any suspicious activity potentially violating AML regulations is reported to the appropriate authorities. They are required, by law, to follow the policy and report any suspicious activity, even if they only suspect a breach.

6. Training and Register Management

6.1. Regular Anti-Money Laundering Training
Our commitment to your safety and satisfaction also extends to our team. We provide ongoing training to ensure all our staff have the knowledge and skills to identify and address AML and FATF regulation risks.

Our management team and external experts lead our comprehensive training program. We ensure that our staff undergo mandatory training on the following topics at least once a year:

  • Curacao anti-money laundering/terrorism financing laws and FATF/CFATF recommendations.
  • Consequences of non-compliance with AML/TF requirements.
  • Awareness of money laundering and terrorism financing types, patterns, and associated risks.
  • Understanding our processes and procedures for identifying, managing, and mitigating AML/TF risks.

Our dedicated and well-trained professionals rigorously verify customer identities and continually monitor operations to prioritize your security. This commitment underscores our dedication to providing a secure and trustworthy environment, empowering our employees with the knowledge to protect your experience with us.

6.2. Register Management
We maintain and securely store various registers as part of our commitment to transparency and compliance. These registers include:

  • Register of established business transactions.
  • Register of ongoing business transactions.
  • Register of terminated business transactions.
  • Register of unusual/suspicious transactions.

For your data’s protection, these registers are stored electronically, and we keep them safe for up to 5 years from terminating our business relations with you.

7. Confidentiality and Continuous Improvement

7.1. Confidentiality Assurance
Rest assured, your data is treated with the utmost confidentiality and security. We do not sell or share your information with any third party. However, in exceptional circumstances where compelled by law or to comply with AML, we may be obligated to disclose information to the relevant authorities of the affected country.

7.2. Commitment to Continuous Improvement
Our pledge to your safety and satisfaction drives our relentless pursuit of continuous improvement at Kirgo. We are dedicated to enhancing our safeguards to ensure your peace of mind while enjoying our services.

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