KYC/AML Policy

1. Introduction

OverBet Gaming is committed to preventing money laundering, terrorist financing, and other financial crimes. This KYC/AML Policy outlines our procedures for verifying the identity of B2B partners and ensuring compliance with international standards.

2. Regulatory Framework

Our KYC/AML procedures comply with:

• Financial Action Task Force (FATF) Recommendations
• Anjouan Offshore Finance Authority regulations
• International gaming industry standards
• Applicable local laws and regulations

3. Customer Due Diligence (CDD)

3.1 Standard Due Diligence

For all B2B partners, we collect and verify:

• Business Information:
  • Legal name and trading names
  • Business registration number
  • Registered address
  • Nature of business
  • Gaming license details
• Beneficial Owners:
  • Full name and date of birth
  • Nationality and residence
  • Government-issued ID (passport, driver's license)
  • Proof of address (utility bill, bank statement)
  • Source of funds documentation
• Authorized Representatives:
  • Identity verification
  • Proof of authorization

3.2 Enhanced Due Diligence (EDD)

Enhanced procedures apply to:

• High-risk jurisdictions
• Politically Exposed Persons (PEPs)
• High-volume or high-value transactions
• Complex ownership structures

4. Verification Process

4.1 Documentation Requirements

Partners must provide:

• Certificate of incorporation
• Articles of association
• Gaming license (certified copy)
• Proof of registered address
• Organizational chart showing beneficial ownership
• Bank account verification
• Source of funds declaration

4.2 Verification Methods

• Document authentication
• Third-party database checks
• Sanctions list screening
• PEP screening
• Adverse media checks

5. Ongoing Monitoring

We conduct continuous monitoring including:

• Regular review of partner accounts (annually or more frequently)
• Transaction monitoring for suspicious activity
• Updates to beneficial ownership information
• License validity checks
• Sanctions list screening updates

6. Risk Assessment

Partners are assigned risk ratings based on:

• Jurisdiction risk level
• Business type and complexity
• Transaction volumes and patterns
• Ownership structure
• Compliance history

Risk ratings determine the level of due diligence and monitoring frequency.

7. Suspicious Activity Reporting

We report suspicious activities including:

• Unusual transaction patterns
• Attempts to avoid reporting thresholds
• Transactions with no apparent business purpose
• Use of multiple accounts for unclear reasons
• Reluctance to provide required information

Suspicious Activity Reports (SARs) are filed with relevant authorities as required.

8. Record Keeping

We maintain records for a minimum of 7 years, including:

• All KYC documentation
• Transaction records
• Risk assessments
• Correspondence and communications
• Due diligence reports

9. Training and Awareness

Our staff receives regular training on:

• AML/KYC regulations and procedures
• Recognizing suspicious activity
• Reporting obligations
• Data protection and confidentiality

10. Sanctions Screening

We screen all partners and their beneficial owners against:

• OFAC (Office of Foreign Assets Control) sanctions lists
• UN Security Council sanctions lists
• EU sanctions lists
• UK HM Treasury sanctions
• Other relevant national and international sanctions

11. Politically Exposed Persons (PEPs)

Enhanced due diligence applies to PEPs, including:

• Senior government officials
• Political party leaders
• High-ranking military officers
• Senior executives of state-owned enterprises
• Close family members and associates of PEPs

12. Consequences of Non-Compliance

Failure to comply with KYC/AML requirements may result in:

• Suspension of services
• Termination of partnership
• Reporting to regulatory authorities
• Legal action

13. Contact Information

For KYC/AML inquiries, contact:

• Compliance Officer: overbetgaming@proton.me
• AML Reporting: overbetgaming@proton.me