Aml Policy

Purpose and scope

The AML policy of Ffbet establishes the measures for detecting, preventing, and reporting money laundering and terrorist financing in relation to all gaming accounts and related payment activities. It applies to all customers and all payment methods offered by Ffbet. Ffbet undertakes a risk based approach and will apply enhanced due diligence for higher risk customers and jurisdictions where required by law.

Regulatory framework

Ffbet complies with applicable anti money laundering and countering financing of terrorism laws and supervisory requirements. The policy is reviewed at least annually and whenever material changes occur. The policy supports internal procedures supporting KYC due diligence, ongoing monitoring, and reporting obligations.

Definitions

  • Money laundering means the concealment of the origin of funds derived from illicit activity by transfer or disguising funds to appear legitimate.
  • Terrorist financing means providing funds or financial services that support terrorist acts or organizations.
  • Source of funds and source of wealth definitions
  • Beneficial owner, Politically Exposed Person PEP
  • Ongoing monitoring, transaction monitoring, suspicious activity reporting SAR
  • Sanctions screening

Know Your Customer and due diligence

Onboarding is designed to verify identity and assess risk before enabling withdrawal or high risk activities. Ffbet uses a three step verification process with escalating checks based on risk and transaction activity:

  1. Step one verification is required for all new customers. Collect full legal name, date of birth, nationality, residential address, and contact information. Obtain a government issued identity document such as a passport, national ID card, or driving license. Verify identity using independent, reliable data sources. Ensure identity and address match the information provided. Step one verification may be completed electronically unless documents indicate otherwise.
  2. Step two verification is triggered when deposits or withdrawals exceed two thousand USD within a rolling 30 day period or when transfers to another user exceed one thousand USD. Step two requires submission of an official photo ID and a proof of address document. An electronic check compares the data on the document with reference databases. If the check fails, the customer will be required to supply additional documents or confirm residence.
  3. Step three verification is triggered when deposits or withdrawals exceed five thousand USD or transfers exceed three thousand USD. Step three requires demonstration of source of funds and reasonable source of wealth documentation such as corporate ownership or employment documentation. Access to certain functions may be restricted until Step three is satisfied.

Ongoing monitoring and transaction monitoring

Ffbet conducts ongoing monitoring of customer activity to identify unusual patterns. Monitoring is performed by a first line control with payment providers and a second line control by the AML compliance team. Unusual patterns include large rapid transfers inconsistent with known business or personal activity, changes in funding sources, inconsistent geolocation or device data, or multiple accounts controlled by the same user. All suspect activity is escalated in accordance with internal procedures and reported to the competent authorities as required.

Source of funds and wealth

Customers with activity above defined thresholds must provide documentation to establish the legitimate origin of funds and the source of wealth. Acceptable SOW evidence includes corporate ownership structures, employment letters, tax returns, and bank statements. Ffbet will freeze the account if unable to verify the source of funds or if there is a risk of illicit activity until verification is resolved.

Sanctions and risk-based screening

Ffbet screens customers against sanctions lists and politically exposed persons as part of the onboarding and ongoing screening process. Where a match occurs, actions including restrictions on payments and reporting to authorities will be taken in compliance with applicable law.

Record keeping

Ffbet retains records of identity verification, KYC information, and transactional data for a minimum of ten years after the end of the business relationship or last transaction. Records are stored securely with access limited to authorized personnel and retained in accordance with applicable law.

Suspicious activity reporting

In accordance with legal obligations, suspected money laundering or terrorist financing must be reported internally without delay and to the appropriate financial intelligence unit as required. The AML compliance officer coordinates reporting and ensures timely escalation processes. Reports retain de-identified information and remain accessible for regulatory review.

Roles and responsibilities

The AML compliance officer leads the program and reports to senior management. The board and executive team approve risk based policies and authorize the escalation of unusual activity. Department heads ensure staff training and adherence to this policy.

Training and awareness

Ffbet conducts regular AML training for staff with content tailored to roles. Training covers KYC procedures, transaction monitoring, escalation paths, data privacy, and record keeping requirements. Training records are maintained for at least five years.

Data protection and privacy

Personal data obtained for AML purposes is processed in accordance with data protection laws. Access is limited to authorized personnel and data is stored securely with encryption and robust access controls. Data transfers to external service providers follow written data processing agreements.

Policy review

This policy is reviewed annually or on material change in laws or guidance. Updates are approved by the AML compliance officer and communicated to staff and customers as appropriate.