Kyc Policy

Purpose and scope

This Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) and Know Your Customer (KYC) Policy governs all activity on the Ffbet platform. It establishes the requirements for customer identification, risk assessment, ongoing monitoring, and escalation to ensure compliance with applicable laws and regulatory guidance for remote gaming operators.

Regulatory framework

Ffbet operates under the Curaçao regulatory regime for online gaming and adheres to relevant AML/CFT legislation and supervisory guidance. The policy is designed to implement the statutory obligations pertaining to customer due diligence, record keeping, reporting of suspicious activity, and governance structures appropriate to a licensed gaming operator.

Risk-based approach

Ffbet employs a risk-based framework to determine the level of due diligence for each customer. The risk model incorporates the following dimensions: customer risk, product/service risk, transaction risk, and geographical risk. Onboarding and ongoing monitoring are calibrated to the assessed risk, with enhanced controls applied where risk is higher as described in this policy.

Customer due diligence (CDD) and identification

  • Collect and verify information enabling the reliable identification of the customer prior to establishing a business relationship. Acceptable evidence includes government-issued identity documents and proof of current address. Verification is conducted using at least two independent sources where feasible.
  • Obtain full name, date of birth, residential address, contact details, and the nature and purpose of the gaming relationship. Maintain a risk profile for each customer reflecting purpose, expected activity, and source of funds.
  • For higher-risk customers or where ownership is through a third party, verify beneficial ownership. Require a declaration of the source of funds for transactions presenting elevated risk or unusual patterns, and verify consistency with the customer profile.
  • Reassess identity information and profile data on a risk-sensitive basis during the course of the relationship and update documentation as needed.

Enhanced due diligence (EDD)

EDD is required where a customer presents heightened risk. Triggers include high geographical risk, corporate or complex ownership structures, unusual transaction patterns, or the involvement of politically exposed persons (PEPs). EDD measures may include additional identity checks, verification of source of funds, enhanced transaction monitoring, and periodic review of the customer’s activity and risk profile.

Politically exposed persons (PEPs)

Customers identified as PEPs or their associates are subjected to enhanced due diligence and ongoing monitoring. Senior management approval is required for onboarding such customers, and monitoring is maintained for the duration of the relationship.

Ongoing monitoring and transaction screening

Ffbet monitors customer activity on a risk-based basis to detect inconsistent or suspicious patterns. The monitoring includes analysis of deposits, withdrawals, bet sizes, and velocity of activity relative to the customer’s profile. Any changes in risk profile prompt a review and, if warranted, a re-application of CDD/EDD measures.

Record keeping and data retention

Ffbet maintains comprehensive records to support AML/CFT investigations. Records include: customer identification and verification data, customer risk assessments, transaction records, evidence of EDD, internal SARs and disclosures, training records, and communications with the nominated officer. Records are retained in accordance with applicable law and regulatory guidance, and for the minimum period required by regulators, or as otherwise directed by the supervisory authority.

Suspicious activity reporting (SARs) and disclosure

Any employee who knows or suspects that a customer is engaged in money laundering or financing of terrorism must report to the designated Money Laundering Reporting Officer (MLRO) promptly and in a manner that preserves confidentiality. Disclosure to the customer or other involved persons is strictly prohibited (tipping off). The MLRO is empowered to assess, escalate, and coordinate external reporting where appropriate, and has the authority to engage law enforcement or regulatory authorities as required.

Withdrawal and deposit controls

Before processing withdrawals, the following checks are performed: (1) review of the customer’s deposit history to confirm normality of deposits relative to the customer’s profile; (2) assessment of turnover to confirm that the customer has engaged with the platform for genuine activity; (3) where feasible, funds are returned to the original payment method used for deposits. Withdrawals and related activity are monitored against the customer’s risk profile and profile updates are performed as needed.

Roles and governance

Senior management retains responsibility for the implementation of this policy. The Money Laundering Reporting Officer (MLRO) is a designated officer with independent authority to receive disclosures, coordinate SARs, and interface with regulators. The Compliance Officer supports enforcement, training, and policy governance. A Compliance Committee or equivalent governance body shall meet at least quarterly to review risk, controls, and the effectiveness of AML/CFT measures and report to the board.

Staff training and awareness

All staff receive initial and ongoing AML/CFT training covering: customer due diligence processes (including enhanced requirements for high-risk clients and PEPs), recognition of suspicious activity, reporting procedures, and internal escalation channels. Training emphasizes personal accountability and compliance with legal obligations and internal procedures.

High-risk jurisdictions and sanctions

Ffbet applies enhanced scrutiny to customers and counterparties from jurisdictions identified as high risk by FATF or the competent regulator. Where appropriate, onboarding from such jurisdictions is subject to enhanced due diligence, ongoing monitoring, or refusal based on the risk assessment. Sanctions screening is conducted against applicable lists, and restricted or blocked activity is enforced in accordance with regulatory guidance.

Employee vetting and internal controls

New staff undergo identity verification and background checks, including verification of credentials by independent references. Internal controls are designed to prevent internal misuse of assets and information, and to ensure sound separation of duties for critical AML/CFT activities.

Policy review and updates

This policy is reviewed at least annually or upon material regulatory change. The MLRO and Compliance Officer coordinates updates, with approval from senior management and notification to relevant stakeholders.