Anti Money Laundering Policy on Pin Up Casino Bangladesh


1.1 Fund Purification

The act of laundering money involves the intricate concealment of pecuniary assets accrued through illicit means, such as narcotics distribution or acts of terror, making them appear as if derived from bona fide sources. Malefactors engage in this facade by either camouflaging the genesis of these assets, transmuting their form, or transporting them to locales less prone to scrutiny.

1.2 Anti-Fund Purification Measures

This term encapsulates the statutory mandates that oblige fiscal institutions and other regulated bodies to obstruct, discern, and report attempts at money laundering. A robust framework against money laundering necessitates:

  • Legislative criminalization of the laundering of funds
  • Empowering regulators and law enforcement with investigative capacities and tools
  • Mandating financial entities to verify clientele identities, establish risk-oriented controls, maintain meticulous records, and report any atypical transactions
  • Facilitating the exchange of pertinent information across borders when necessary

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Those employed within the distant gaming sector must report any intel that arises in their professional dealings:

  • Upon certain knowledge
  • Upon suspicion
  • Upon having reasonable grounds for suspicion that an individual is implicated in money laundering or financing terrorism, inclusive of illicit expenditures. This collective requirement to report is driven by the necessity to prove, via corroborative evidence, that a risk evaluation was performed before initiating business relations and that thorough customer due diligence is executed to align customer transactions with their risk profile.

Merchants must demonstrate that ongoing surveillance measures are adapted to the level of risk and that all records are preserved to reflect this, with risk profiles meticulously updated. Here, we detail additional procedures applied for enhanced risk monitoring and circumstances necessitating a Declaration from customers concerning their source of funds in high-risk scenarios.

2.1 Specific Regulations

Our commitment extends to integrating compliance across all business facets, upheld by the licensed Curacao Gaming License which permits the operation of Internet-based games of chance globally.

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Crime & Disorder and Anti-Money Laundering Strategy

Our strategy is founded on principles and practices that:

  • Develop suitable systems and controls for our businesses to adhere to legal standards
  • Regularly reassess these systems and controls
  • Maintain records to support law enforcement in addressing money laundering and terrorist financing
  • Ensure comprehensive training for all relevant staff and provide our nominated officer with the necessary resources and autonomy to perform effectively

Risk Management

Our approach to risk management involves:

  • Identifying relevant risks of money laundering and terrorist financing
  • Crafting and implementing strategies to mitigate these risks
  • Continually monitoring and refining these strategies
  • Documenting our processes and their rationale

Suspicious Activity

Here, suspicious activity pertains to unusual transactions, discrepancies in player profiles, and mismatches in deposit amounts, among other indicators. Enhanced due diligence is mandated for players who exhibit these risks:

  • Identification documentation such as a passport or ID card.
  • Proof of residence like a utility bill or bank statement.
  • Further evidence of identity as needed.

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Suspicious Activity Reports (SARs)

SARs are a compulsory element of our framework, necessitating confidential, discreet handling to maintain utmost anonymity. It is paramount that no employee discloses any concerns related to Anti-Money Laundering investigations to the involved parties or others, as such disclosure is legally punishable.

Withdrawal Procedures

Before processing withdrawals, we rigorously review the customer's deposit history and betting patterns to ensure no anomalies suggest money laundering activities. This includes verifying that funds are returned to the original payment methods wherever feasible.

Staff Training

All staff undergo training to comprehend their obligations under the Money Laundering Regulations and are informed about the escalation procedures for any suspected activities to the Money Laundering Reporting Officer (MLRO). The MLRO is empowered to act independently and has access to adequate resources to fulfill their duties effectively.

High-Risk Jurisdictions

Countries identified by the Financial Action Task Force or our internal assessments as high-risk are subject to enhanced due diligence, reflecting the heightened threat they pose.

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Record Keeping

Our record-keeping practices are designed to support any financial investigations, ensuring we maintain detailed records of compliance monitoring, customer identification, and transactions.

Compliance and Risk Committee

This committee, comprising the MLRO, Compliance Officer, and a non-executive director, meets regularly to review risks and ensure that our practices align with statutory requirements.

Supplier Selection

We rigorously assess potential suppliers to ensure they meet our standards of financial stability, legal compliance, and ethical business practices, rejecting those that do not align with our risk management framework.

Proceeds of Crime Act Compliance

We are acutely aware of our obligations under the Proceeds of Crime Act and have instituted policies to ensure compliance with this legislation.

Data Protection

To safeguard customer data and prevent internal fraud, we enforce strict security policies and controls, including encryption, access controls, and network management.