Version as of August 1, 2023
1. Introduction
1.1. www.betkin.com is operated by StepX B.V. having its office at: Heelsumstraat 51, E-Commerce Park Vredenberg, Curaçao, the mailing address: Chuchubiweg 17, Curaçao, Company Registration number 156454.
2. AML-KYC Policy aims and goals
2.1. Betkin.com aspire to supply the highest quality, security, and comfort to all of our users and customers. While remaining fully compliant with all anti-money laundering laws (AML) and its customer knowledge (KYC) requirements. For that reasons a three-step account verification is implemented in order to insure our customers correct identification.
2.2. We are doing the best to make the AML-KYC procedures comfortable and easy for the user. The essence of these AML-KYC procedures is to ensure that:
- the details of the person registered are correct and accurate;
- the person is not associated with money laundering, financing of terrorism and other criminal activities;
- the deposit funds used are not stolen or being used by someone else, and are not associated with criminal activities.
2.3. Determination of the above circumstances creates the general framework for knowledge of the customer and for fight against money laundering.
2.4. As well we pay attention to such a basic risk markers as nationality and origin, the way of payment and withdrawing.
2.5. www.betkin.com is committed to the highest standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.
3. Money Laundering Definition
3.1. Money Laundering shall be understood as:
- conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person's or companies action;
- 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 an activity;
- the acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;
- participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points above.
3.2. Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.
4. AML settings in betkin.com
4.1. In accordance with the AML legislation, www.betkin.com has appointed the “highest level” for the prevention of Money Laundering. The full management of StepX B.V. are in charge. Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the Company.
4.2. The AMLCO shall be appointed from senior management or placed under the direct responsibility of the senior management. At the initial stages of the company's operation, while there is still not enough staff and management, a director or a key shareholder-individual can perform the functions of AMLCO.
5. AML-KYC policy changes and implementation requirements
Each major change of www.betkin.com AML policy is subject to be approval by the general management of StepX B.V. and the AMLCO.
6. Legal Compliance
The AML-KYC procedures of betkin.com is designed to be compliant with:
- EU: “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering;
- EU: “Regulation 2015/847 on information accompanying transfers of funds;
- EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
- BE: “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash
7. Three-level User Identification and Verification (KYC)
7.1. Level 1 Verification:
Level one verification is the first step of verification. Every user and customer who want to withdraw shall go through this process as a first step. Also, first level verification can be done by each user on his own, at any time after registration.
The first level of verification consists in filling out an online form on the website containing the following information: first name, last name, date of birth, state of residence, address, and occupation. As part of the first level of verification, no documents are requested.
7.2. Level 2 Verification:
Level two verification is the second step of verification. Every user and customer who want to withdraw shall go through this process as a second step. It is available only after passing first level verification indicated above.
The second level of verification consists in online uploading of documents, confirming information, transferred in the framework of Level 1.
In the second level of verification, the user needs to upload an official personal identification document. Also, for some categories of users (risk level may depends on residence region), the second level of identification involves uploading a document confirming the address (this can be a utility bill or a bank statement with the user's address).
On the second verification level there will also be an electronic check if the filled in data from the step one verification is correct. The electronic check will check via two different databanks to ensure the given information’s matches with the filled document and the name from the ID: If the electronic test fails or is not possible the user/customer is required to send in a conformation of his current resident. A certificate of registration issued by the government, utility bill or a bank statement with the user's address are acceptable.
7.3. Level 3 Verification:
Level three verification is the third (the last one) step of verification. Every user and customer who want to withdraw over 5000 euro shall go through this process as a third step.
In the third level of verification, the user may need to make a selfie with personal ID document, upload a second identification document, documents confirming an address (if not previously provided) and, in some cases, sources of wealth documents. Documents showing the source of wealth can be bank statements, tax returns, property sales contracts, and other suitable documents that show the source of wealth.
8. Additional measurements
8.1. Programming solution overseen by the AMLCO will look for any unusual behaviour and report it right away to a employee of www.betkin.com.
8.2. According to a risk based general experience, the human employees will recheck all the checks which are done by the above Programming solution or other employees and may redo or do additional checks according to the situation.
8.3. In addition, a data operator supported by modern electronic, analytic systems will look for unusual users behaviour like:
- depositing and withdrawing without longer betting sessions;
- attempts to use a different Bank account for Deposit and Withdraw
- territory changes, currency changes, behaviour and activity changes as well as checks, if an account is used by it´s original owner.
Also a User has to use the same method for Withdraw as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.
9. Enterprise-wide risk assessment
9.1. As part of its risk-based approach, www.betkin.com conduct an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to www.betkin.com and its business lines.
9.2. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers.
9.3. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.
9.4. The identification of AML risk categories is based on www.betkin.com understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.
9.5. The EWRA is yearly reassessed.
10. Ongoing transaction monitoring
10.1. AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile.
10.2. This transaction monitoring is conducted on three levels:
1) The first Line of Control:
www.betkin.com works solely with trusted Payment Service Providers whom all have effective AML policies in place as to prevent the large majority of suspicious deposits onto www.betkin.com from taking place without proper execution of KYC procedures onto the potential customer.
2) The second Line of Control:
www.betkin.com makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular these include:
- requests for the execution of financial transactions on the account;
- requests in relation to means of payment or services on the account;
3) The third Line of Control:
As a last line of defence www.betkin.com will do manually checks on all suspicious and higher risk users in order to fully prevent money laundering.
10.3. If fraud or Money Laundering is found the authorities will be informed.
10.4. Also, above three-lewel identification and verification with adjusted risk management should provide all necessary information’s about all the costumers of www.betkin.com at all the time.
10.5. Also, all transaction must be overseen by employees over watched by the AMLCO who is over watched by the general management.
10.6. The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.
10.7. Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterparty. These checks will be done by an automated System, while an Employee crosschecks them for additional security.
10.8. The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must therefore rapidly be considered atypical (as they are not directly justifiable).
10.9. Any www.betkin.com staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.
11. Reporting of Suspicious transactions on www.betkin.com
11.1. In its internal procedures, www.betkin.com describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
11.2. Reports of atypical transactions are analysed within the AML team in accordance with the precise methodology fully described in the internal procedures.
11.3. Depending on the result of this examination and on the basis of the information gathered, the AML team:
- will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
- will decide whether or not it is necessary to terminate the business relations with the customer.
12. Procedures
The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of www.betkin.com.
13. Records keeping
13.1. Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.
13.2. Records of all transaction data must be kept for at least ten years following the carrying out of the transactions or the end of the business relationship.
13.3. These data will be safely, encrypted stored offline and online.
14. Training
14.1. Betkin.com human employees will make manual controls on a risk based approve for which they get special training.
14.2. The training and awareness program is reflected by its usage:
- a mandatory AML training program in accordance with the latest regulatory evolutions, for all in touch with finances;
- academic AML learning sessions for all new employees.
14.3. The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML-specialist working StepX B.V. AML team.
15. Auditing
Internal audit regularly establishes missions and reports about AML-KYC activities.
16. Data Security
16.1. All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.
16.2. www.betkin.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)
17. Contact us
17.1. If you have any questions about our AML and KYC Policy, please contact us by e-mail: support@betkin.com
17.2. If you have any complains about our AML and KYC Policy or about the checks done on your Account and your person, please contact us by e-mail: AML@betkin.com