AML Policy of bitstrike.io

bitstrike.io (“the Website”) is operated by Zosma LLC, a limited liability company registered in Belize with company registration number IFSC/200/LLC 2125/23 with registered address at New Horizon Building, Ground Floor, 3 1/2 Miles Philip S.W. Goldson Highway, Belize City, Belize (“Company”, "We").

We developed a comprehensive risk-based Anti-Money Laundering and Countering the Financing of Terrorism Policy (“the Policy”) for our website in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering. The Policy outlines the principles and minimum standards of internal AML controls which should be adhered to by the Company to mitigate reputational, regulatory, legal and financial loss risks.

This document is intended to outline the Company’s AML policie s and procedure s in order to ensure that:

• Statutory and regulatory obligations to prevent money laundering and financing of terrorism are met, taking positive action in order to minimize risk of the Company’s services being used for the purpose of laundering the proceeds of criminal activity or terrorist financing.
• The Company does not engage with or continue established relationships with those whose conduct gives rise to suspicion of involvement with illegal activities. We will seek to terminate any relationship where conduct gives the Company reasonable cause to believe or suspect involvement with illegal activities.
• Any such termination shall follow the reporting of the suspicions and thereafter shall be undertaken in conjunction with the relevant authorities and in accordance with the relevant regulations to avoid any risk to the Company.
• The Company complies with the obligations of relevant national and international legislation and regulation, adherence to Financial Action Task Force (FATF) recommendations, EU Directives and other applicable laws and regulations on the prevention of money laundering and financing of terrorism.

The Company is committed to high standards of anti-money laundering compliance and requires management and employees to adhere to these standards in preventing the use of its products for money laundering/financing of terrorism.

Money Laundering is defined as:

1. The conversion or transfer of property, knowing that such property is derived from criminal activity or from participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;
2. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
3. The acquisition, possession or use of property, knowing, at the moment of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
4. The participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to points 1, 2 and 3;

There are often three acknowledged phases of money laundering:

• Placement – the physical disposal of cash or other assets derived from criminal activity.
• Layering – the separation of the illicit proceeds from their source by layers of transactions intended to hide the origin of the funds.
• Integration – supplying apparent legitimacy to illicit wealth through the re -entry of the funds into the economy in what appear to be personal transactions. However, even simple possession of criminal property may constitute an offence. Criminal property is defined as property which is, or represents, a person’s benefit from criminal conduct, where the alleged offender knows or suspects that it is such.

The risk -based approach recognizes that the AML risks faced by each sector and each subject person are different and allows for resources to be invested and applied where they are most required. The risk -based approach envisages the application of checks that are proportionate to the assessed risk. The cornerstone of the risk -based approach is the risk assessment which must be carried out at different stages of a subject person’s activities. This assessment allows the subject person to identify its AML vulnerabilities and the AML risks it is exposed to.

Know Your Customer Procedures are followed to achieve the following objectives:

• Allowing only legitimate customers to register an account (i.e., to exclude from registration the following categories: Minors, Sanctioned Persons or Players from Sanctioned countries are not allowed to register a gaming account).
• Build the risk profile associated with the customer.
• Confirming that customers are who they say they are.
• Monitoring customer accounts and transactions for illegal activities.
• Blocking duplicate accounts.
• Identifying possible PEP & customers from countries identified as having significant levels of corruption or other criminal activity.

As per the money laundering regulations, we utilize three stage s of due diligence checks, depending on the risk, transaction, and customer type:

SDD — simplified due diligence i s used in instance s of extremely low-risk transactions that do not meet the required thresholds.

CDD — customer due diligence i s the standard for due diligence checks, used in most cases for verification and identification.

EDD — Enhanced Due Diligence i s used for high-risk customers, large transaction s or special cases.

Separately and in addition to the above, in all cases, users must complete the full KYC process before initiating their first fiat withdrawal, regardless of the amount. In addition, KYC is compulsory when a user makes an aggregate lifetime total of deposits exceeding EUR 5,000 or attempts or completes a transaction that is deemed suspicious.

During this process, the user will have to input some basic detail s about themselves and then upload:

1. A copy of Government Issued Photo ID (in some cases front and back depending on the ID document)
2. A selfie of themselves holding the ID doc
3. A bank statement/Utility Bill

1) Proof of ID

a. Signature is there

b. Country is not one of the following Restricted Countries:

• Austria
• Australia
• France and its territories
• Germany
• Netherlands and its territories
• Spain
• Union of Comoros
• United Kingdom
• USA and its territories
• All FATF Blacklisted countries,
• any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority.

c. Full Name matches client’s name

d. Document does not expire in the next 3 months

e. Owner is over 18 years of age

2) Proof of Residence

a. Bank Statement or Utility Bill

b. Country is not one of the following Restricted Countries:

• Austria
• Australia
• France and its territories
• Germany
• Netherlands and its territories
• Spain
• Union of Comoros
• United Kingdom
• USA and its territories
• All FATF Blacklisted countries,
• any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority.

c. Full Name matches client’s name and is same as in proof of ID.

d. Date of Issue: In the last 3 months

3) Selfie with ID

a. Holder is the same as in the ID document above

b.ID document is the same as in “1”. Make sure photo/ID number is the same

1. When the KYC process is unsuccessful then the reason is documented and a support ticket is created in the system. The ticket number along with an explanation communicated back to the user.
2. Once all proper documents are in our possession then the account gets approved.

In cases where players, products or transaction are deemed to be of higher risk, Enhanced Due Diligence (EDD) procedures should apply. The following events should trigger the EDD 5 procedures:

• Player is a PEP (Politically Exposed Person) or becomes a PEP after establishing business relationship with the Company.
• Duplicate IPs.
• IP shifting.
• Country of origin associated with higher credit card fraud.
• Attempts to create multiple accounts.
• Attempting to withdraw funds without using the funds to play (withdrawal without making any bets or starting any game session).
• Sudden changes in account activity.
• The registered country is not part of the FATF whitelist, or the registered country is any other country that appears associated with higher risk of money laundering, terrorist and proliferation financing, as well as countries identified as having significant levels of corruption or other criminal activity.
• Noticeable changes in the gaming patterns of customer, such as when the customer carries out transactions that are significantly larger in volume when compared to the transactions he/she normally carries out.
• Customer carries out transactions which seem to be disproportionate to their wealth, known income or financial situation.
• Size and frequency of transactions raise suspicions. Sudden changes in account activity e.g., the volume of transaction increases suddenly.
• The Company has doubts about the accuracy or adequacy of previously obtained customer identification data.

Enhanced Due Diligence (EDD) will automatically apply to all large fiat withdrawals exceeding EUR 10,000.

For every account deemed as High Risk an Enhanced Ongoing Monitoring of the business relationship will be conducted.

In situations where EDD check is required the customer must submit also:

• Bank statement (not older than 3 months).
• Proof of the source of funds.
• Payment method confirmation (if required).

If the customer does not send these documents within 30 days, the gaming account will be blocked from all transactions. The account also can be suspended (access to account temporarily restricted) until provision of the requested documents depending on relevant risk level.

Other EDD measures applied by the Company depending on the risk level defined:

• Obtaining additional information on the customer (e.g., occupation, volume and assets, information available through public databases, internet etc.) and updating more regularly the identification data of customer.
• Obtaining necessarily detailed information and explanations on the source of funds or source of wealth of the customer.
• Obtaining the approval of senior management to commence, terminate or continue the business relationship.
• Conducting enhanced monitoring of the business relationship, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.

We conduct manual check of customer’s withdrawals. Any suspicious withdrawal leads to Enhanced DD and freezing of the customer’s account. Enhanced DD includes i) obtaining additional information on the customer (e.g., occupation, volume and assets, information available through public databases, internet etc.); ii) obtaining information on the source of funds or source of wealth of the customer; iii) obtaining the approval of senior management to commence or continue the business relationship.

We conduct ongoing and regular monitoring of potentially risk placement of funds by customers. In case of suspicious placement of funds customer’s account and funds are freezed and enhanced due diligence is conducted.

We develop risk profiles to determine the customer categories which expose the Company to higher risk. High risk customers include: customers from countries identified as not having adequate AML systems, customers from countries subject to sanctions, embargos or similar measures imposed by the UN, customers from countries identified as having significant levels of corruption or other criminal activity, customers from countries or geographic areas identified as providing funding or support for terrorist activities, or that have designated terrorist organizations operating within their country.

There is a number of events which might raise suspicions of money laundering, and which require further scrutiny. The following are listed below (but not limited to):

• Customer does not cooperate in the carrying of customer due diligence.
• Customer attempts to register more than one account with the same website.
• Customer deposits considerable amounts during a single session by means of multiple payment methods.
• Customer deposit funds well in excess of what is required to sustain their usual betting patterns.
• Customer makes small wagers even though he/she has significant amounts deposits, followed by a request to withdraw in e xcess of any winnings.
• Customer makes frequent deposits and withdrawal requests without any reasonable explanation.
• Noticeable changes in the gaming patterns of a customer, such as when the customer carries out transactions that are significantly larger in volume when compared to the transactions he/she normally carries out.
• Customer enquiries about the possibility of moving funds between accounts (websites) belonging to the same gaming license.
• Customer carries out transactions which seem to be disproportionate to their wealth, known income or financial situation.
• Customer seeks to transfer funds to the account of another customer or to a bank account held in the name of a third party.
• Customer displays suspicious behavior in playing games that are considered as high risk.
• Artificially splitting a withdrawal to remain “below the radar”.
• Unexplained or unclear source of wealth e.g., student playing large volumes of money the source of which cannot immediately be ascertained.
• Sudden changes in account activity e.g., the volume of transaction increases suddenly.

We keep for at least 5 (five) years all records obtained through due diligence measures and documentation regarding our relations with customers and customers’ transactions, as well as correspondence with the customers.

This information could be required on a timely basis by regulatory authorities. The documents as outlined should be kept for 5 years from the date of the transaction or the date of completion of any related transaction. Customer due diligence information, or copies thereof, must also be kept for a minimum of 5 years from the date the person concerned ceases to be a registered customer or from the date of the customers most recent activity. These records can be kept in documentary or electronic format.