AML Policy of PrimeWin N.V. for Deposits and Withdrawals

1.Introduction

The operation of http://primewin.com (the "Website") is managed by PrimeWin N.V., a company registered and established under the laws of Curaçao, with registration number 165439 and registered address at Zuikertuintjeweg Z/N (Zuikertuin Tower) Curaçao, and its wholly-owned subsidiary, PrimeByte Solutions Ltd, registered in Cyprus with registration number HE455186 and registered address 6 Othonos, Strovolos, 2008, Nicosia, Cyprus. PrimeWin N.V. is licensed and regulated by Gaming Services Provider N.V. (license no. 365/JAZ). 

In our commitment to providing the highest level of security for all users and customers on the Website, a three-step account verification process is employed. This verification aims to confirm the accuracy of registered user details and ensure that the deposit methods employed are legitimate and not being utilized by unauthorized individuals. This framework is essential in the ongoing efforts to combat money laundering. Recognizing the diverse nationalities and origins of our users, we implement varying safety measures for payment and withdrawal procedures.  

We have implemented reasonable measures to control and mitigate money laundering (the ML) risks, allocating appropriate resources for this purpose.  

For terms capitalized within this document and not explicitly defined herein, the interpretations shall align with the definitions provided in our Terms and Conditions. It is imperative for users and customers to refer to the comprehensive definitions outlined in the Terms and Conditions for a clear understanding of the terminology employed in the context of this Anti-Money Laundering (AML) Policy. This practice ensures consistency and clarity in the interpretation of key terms throughout our regulatory framework.

2.Compliance Standards

The Company upholds rigorous anti-money laundering (AML) standards in accordance with EU guidelines. Our management and employees are mandated to enforce these standards to prevent the utilization of our services for money laundering purposes.  

The AML program applicable to the users of the Website aligns with the following EU directives and regulations:

• Directive 2015/849: European Parliament and Council Directive of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering.
• Regulation 2015/847: Regulation on information accompanying transfers of funds.  
   
• Various EU Regulations: Imposing sanctions or restrictive measures against individuals and embargoes on certain goods and technology, including dual-use goods.

Additionally, the AML program complies with Belgian law:  

Law of 18 September 2017: On the prevention of money laundering and limitation of the use of cash.  

The Company remains dedicated to maintaining and updating its AML program to align with evolving regulatory requirements and to foster a secure and compliant environment for its users and customers.

3.Definition of money laundering

Money Laundering is defined as follows:  

Conversion or Transfer - the act of converting or transferring property, especially money, with the knowledge that such property is derived from criminal activity or active participation in such activity. The purpose is to conceal or disguise the illicit origin of the property or assist any person involved in the criminal activity in evading legal consequences.  

Concealment or Disguise - the act of concealing or disguising the true nature, source, location, disposition, movement, rights with respect to, or ownership of property. This is done with the knowledge that such property is derived from criminal activity or an act of participation in such activity.  

Acquisition, Possession, or Use - the act of acquiring, possessing, or using property with the knowledge, at the time of receipt, that such property was derived from criminal activity or assisting in such activity.  

Participation, Association, Attempts, and Aid - inclusive of participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the actions mentioned above.  

It is important to note that money laundering is recognized as such even when the activities generating the laundered property occurred in the territory of  the third country. This comprehensive definition ensures the encompassing understanding and identification of money laundering activities within our regulatory framework.

4.Organization of the Anti-Money Laundering   
(AML) Framework for the Website

In adherence to AML legislation, http://primewin.com has established a robust organizational structure for the prevention of money laundering, with the highest level of authority designated to the full management of the Company.   

Key Roles:  

1. Full Management:  
The full management team of PrimeWin N.V. is collectively responsible for the oversight and prevention of money laundering activities.  

2. Anti Money Laundering Compliance Officer (AMLCO)  

An AMLCO is appointed to ensure the enforcement of the AML policy and procedures within the system. The AMLCO operates under the direct responsibility of the general management.  

AML Policy Changes and Approval  

Any significant alteration to the AML policy of http://primewin.com requires approval from both the general management of PrimeWin N.V. and the Anti Money Laundering Compliance Officer.  

Three-Step Verification Process  

Step One Verification:

• Mandatory for every user and customer intending to make withdrawals.
• Required irrespective of the chosen payment method, withdrawal amount, withdrawal method, or user nationality.
• Step one verification involves completing a document with the following information: first name, second name, date of birth, country of usual residence, gender, and full address.

Step Two Verification:

• Mandatory for users depositing over 2000 EUR or withdrawing any amount.
• Withdrawals, tips, or deposits will be held until step two verification is completed.
• Users must submit a picture of their official ID, accompanied by a paperclip with a six-digit random generated number.
• An electronic check verifies the accuracy of data from step one verification against two different databases.
• In case of an electronic check failure, users are required to submit confirmation of their current residence, such as a government-issued certificate of registration.

Step Three Verification:

• Mandatory for users depositing over 5000 USD, withdrawing over 5000 USD, or sending another user over 3000 USD.
• Withdrawals, tips, or deposits are held until step three verification is completed.
• Users must provide a source of wealth for step three verification.

These verification steps aim to ensure the security and integrity of the platform, safeguarding against potential money laundering risks.

5.Customer identification and verification (KYC)

Formal identification of customers at the commencement of commercial relations is a critical component, mandated by both anti-money laundering regulations and the KYC policy. The following principles form the foundation of this identification process:  

1. Document Submission:

• Users/customers are required to provide a copy of their passport, ID card, or driving license.
• Each document must be presented alongside a handwritten note containing six randomly generated numbers.
• Additionally, users/customers must submit a second picture featuring their face. For privacy, users/customers may blur out all information except for date of birth, nationality, gender, first name, second name, and the facial image.

2. Document Format:

• All four corners of the ID must be visible in a single image.
• Every detail on the ID, especially the aforementioned information, should be clearly readable.
• The platform reserves the right to request all details if deemed necessary.

3. Privacy Considerations:

• Users/customers have the option to obscure certain details on the provided documents to safeguard their privacy.
• However, the specified details (date of birth, nationality, gender, first name, second name, and facial image) must remain visible and unaltered.

4. Additional Checks:

• In certain situations, an employee may conduct additional checks as deemed necessary to enhance the verification process.

Users are encouraged to adhere to these guidelines to facilitate a smooth onboarding process and contribute to a secure and transparent user environment.

6.Proof of Address

Verification of address is conducted through two distinct electronic checks, utilizing separate databases. In the event of an electronic test failure, users/customers have the option to submit manual proof.  

Acceptable forms of proof include:

• A recent utility bill sent to the registered address, issued within the last three months.
• An official government document verifying the state of residence.

To expedite the approval process, ensure that the document submitted has a clear resolution, displaying all four corners and readable text. Examples of suitable documents include an electricity bill, water bill, bank statement, or any government-issued correspondence addressed to the user. Additional checks may be conducted by an employee if deemed necessary based on the situation.

7.Source of Funds (SOF)

For deposits exceeding five thousand euros, a thorough understanding of the source of wealth (SOW) is required. Examples of SOW include ownership of a business, employment, inheritance, investment, or family-related sources.  

It is crucial to clearly comprehend the origin and legitimacy of the accumulated wealth. If verification is not possible, an employee may request additional documentation or proof. In cases where a user deposits this amount in a single transaction or through multiple transactions totalling this amount, the account will be frozen. An email will be manually sent to the user, providing instructions for the necessary verification steps, and information will be available on the website.  

In addition to verifying the source of funds, http://primewin.com may request a bank wire or credit card information to further ensure user identity. This process also provides supplementary details about the financial situation of the user.  

Basic document for step one: 

• The basic document will be accessible via the setting page on http://primewin.com. Every user has to fill out the following information’s: 
• First name 
• Second name
• Nationality
• Gender 
• Date of Birth 

The document will be saved and created by an AI, an employee may do additional checks if necessary based on the situation.

8.Risk Management

To effectively address varying risks and diverse states of wealth in different regions worldwide, http://primewin.com implements a risk management strategy by categorizing nations into three risk regions.  

Region One - Low Risk:

• For nations classified as low risk, the three-step verification process, as described earlier, will be applied uniformly.

Region Two - Medium Risk:

• For nations falling into the medium-risk category, the three-step verification will be conducted at lower deposit, withdrawal, and tip amounts.
• Step one will follow the standard procedure.
• Step two will occur after depositing $1000, withdrawing $1000, or tipping another user $500.
• Step three will be implemented after depositing $2500, withdrawing $2500, or tipping another user $1000.
• Additionally, users from low-risk regions engaging in cryptocurrency transactions with any other currency will be treated similarly to users/customers from a medium-risk region.

Region Three - High Risk:

• High-risk regions will be prohibited from accessing http://primewin.com.
• Regular updates will be performed to stay current with the dynamic global landscape.

This risk categorization ensures a tailored approach to verification processes, aligning with the perceived risk level of each region. The strategy aims to strike a balance between security measures and user convenience, adapting to the changing dynamics of the online environment.

9.Additional Measures

To augment our anti-money laundering (AML) efforts, http://primewin.com employs a multifaceted approach that includes both human oversight and advanced technological systems.  

Artificial Intelligence Oversight:

• An AI system, overseen by the AML compliance officer, actively monitors user behavior for any unusual patterns. Any detected anomalies are promptly reported to http://primewin.com employees.

Human Verification and Redundancy:

• In alignment with a risk-based view and leveraging general experience, human employees conduct thorough checks, either revalidating or performing additional checks as deemed necessary based on the situation.

Data Scientist Analysis:

• Supported by modern electronic analytic systems, a data scientist examines user activity, specifically looking for unusual behavior such as:
• Depositing and withdrawing without engaging in extended betting sessions.
• Attempts to use different bank accounts for deposit and withdrawal.
• Nationality changes.
• Currency changes.
• Changes in behavior and activity.
• Verification checks to ensure the account is used by its original owner.

Consistency in Withdrawal Method:

• Users are required to use the same withdrawal method as the one used for the initial deposit, and for the amount of the initial deposit. This measure is in place to prevent money laundering attempts.

Enterprise-Wide Risk Assessment (EWRA):

• http://primewin.com has conducted an AML "Enterprise-wide risk assessment" (EWRA) as part of its risk-based approach. This assessment identifies and comprehends risks specific to http://primewin.com, encompassing its business lines, services, user transactions, delivery channels, geographic locations, and other qualitative and emerging risks.

AML Risk Policy Determination:

• The AML risk policy is formulated after identifying and documenting inherent risks related to the website's business lines and services.

Continuous Review and Enhancement:

• The EWRA is revisited annually to ensure it remains current and effective in addressing evolving risks, including those introduced by the dynamic nature of the online environment.

This comprehensive approach reflects our commitment to maintaining the highest standards in AML compliance, utilizing both advanced technology and human expertise to safeguard the integrity of our platform.

10.Ongoing Transaction Monitoring

To proactively detect unusual or suspicious transactions, AML-Compliance at http://primewin.com ensures the implementation of an ongoing transaction monitoring system, operating on two distinct levels:  

The First Line of Control:

• http://primewin.com collaborates exclusively with trusted Payment Service Providers, each adhering to effective AML policies. This collaboration significantly reduces the occurrence of suspicious deposits without proper execution of KYC procedures on potential customers.

The Second Line of Control:

• The network of http://primewin.com is activated to initiate due diligence on any interaction with the customer, player, or authorized representative.
• This includes requests for financial transactions and inquiries related to means of payment or services on the account.
• The three-step verification, coupled with adjusted risk management, ensures the availability of all necessary information about http://primewin.com customers at all times.
• Transactions are overseen by employees, monitored by the AML compliance officer, who, in turn, reports to the general management.
• Specific transactions submitted to customer support managers, possibly through their Compliance Manager, undergo due diligence.
• Automated systems conduct initial checks, followed by crosschecks by employees for enhanced security.
• Transactions on customer accounts with unclear lawful activities and origin of funds are swiftly considered atypical.
• Any http://primewin.com staff member witnessing atypical transactions, unable to attribute them to a known lawful activity or source of income, is obligated to inform the AML division.

The Third Line of Control:

• As a final line of defense against AML, http://primewin.com performs manual checks on all suspicious and higher-risk users.
• In cases of identified fraud or money laundering, authorities will be promptly informed.

This meticulous three-tiered approach to transaction monitoring demonstrates our commitment to preventing money laundering and maintaining the highest standards of compliance. Any potential risks are swiftly identified and addressed through a combination of automated systems, employee oversight, and manual checks. In cases of confirmed fraudulent activities, swift reporting to the authorities is a priority.

11.Reporting of Suspicious Transactions on the Website

Within its internal procedures, http://primewin.com provides precise guidelines for its staff on when and how to report suspicious transactions. Reports of atypical transactions are thoroughly analyzed by the AML team using a defined methodology outlined in internal procedures. Based on the examination results and gathered information, the AML team:

• Decides whether it is necessary to submit a report to the FIU, aligning with legal obligations outlined in the Law of 18 September 2017.
• Determines whether or not it is necessary to terminate business relations with the customer.

12.Procedures

AML rules and minimum KYC standards are translated into operational guidance or procedures available on the Intranet site of http://primewin.com.

13.Record Keeping

Records of identification data must be retained for at least ten years after the termination of the business relationship.  

Records of all transaction data must be preserved for at least ten years after the completion of transactions or the end of the business relationship.  

Data is securely encrypted and stored both offline and online.

14.Training

Human employees at http://primewin.com conduct manual controls based on risk-based approval, receiving specialized training.  

A comprehensive training and awareness program is mandatory, in compliance with the latest regulatory changes, for all staff involved in financial aspects.  
New employees undergo academic AML learning sessions tailored to their specific roles, conducted by AML specialists within the AML team.

15.Auditing

Internal audit regularly establishes missions and issues reports on AML activities.

16.Data Security

User data is kept secure and will not be sold or shared unless compelled by law or to prevent money laundering. Data may be shared with the AML authority of the affected state in compliance with guidelines and rules of the data protection directive (Directive 95/46/EC).

17.Contact Us

For any questions or complaints about the AML and KYC Policy, users can contact Us via email at [email protected].