AML Policy of Coco Loco Holdings N.V.
Last updated: September 22, 2023
For Cash Deposits and Cash Withdraws.
AML Anti-Money-Laundering policy of www.betcoco.com.
Introduction: betcoco.com is operated by Coco Loco
Holdings NV having its office at Abraham de Veerstraat 9 Willemstad,
Curacao. Company Registration number 162531.
Objective of the AML Policy: We seek to offer the highest
security to all our users and customers on betcoco.com for that a three-step account
verification is done in order to insure the identity of our customers. The
reason behind this is to prove that the details of the person registered are
correct and the deposit methods used are not stolen or being used by someone
else, which is to create the general framework for the fight against money
laundering. We also take into accord that depending on the nationality and
origin, the way of payment and for withdrawing different safety measurements
must be taken.
Betcoco.com also puts reasonable measures in place to
control and limit ML risk, including dedicating the appropriate means. betcoco.com is committed to high 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.
The AML program of betcoco.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
Definition of money laundering:
Money Laundering is understood as:
• The 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;
• 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 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 before. 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.
Organization of the AML for betcoco.com:
In accordance with the AML legislation, betcoco.com has appointed the
“highest level” for the prevention of ML: The full management of Coco Loco
Holdings NV 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 System.
The AMLCO is placed under the direct responsibility of
the General Management of Coco Loco Holdings NV.
AML policy changes and implementation requirements:
Each major change of betcoco.com AML policy is subject to be approval
by the general management of Coco Loco Holdings NV and the Anti money
laundering compliance officer.
Three step Verification:
Step one verification:
Step one verification must be done by every user and
customer to withdraw. Regarding of the choice of payment, the amount of
payment, the amount of withdraw, the choice of withdraw and nationality of the
user/customer step one verification must be done first. Step one verification
is a document that must be filled out by the user/customer himself. The following
information must be filled in: first name, second name, date of birth, country
of usual residence, gender and full address.
Step two verification:
Step two verification must be done by every user who withdraws
over 2000 € (two thousand Euros).
Until step two verification is done the withdraw, tip or deposit will be held.
Step two verification will lead the user or customer to a subpage where he must
send in his ID. The user/customer must submit a bank statement or utility bill issued within
the last 3 months, containing full name and address of the customer and make a
picture of his ID. While a paperclip with a six-digit random generated number
is next to his ID: Only an official ID may be used for ID verification, depending
on the country the variety of accepted IDs may be different. 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 insure
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 by the government or a similar document is required.
Step three verification:
Step three verification must be done by every user who
deposits over 10000
€ (ten
thousand Euros) or withdraws over 5000 € (five thousand Euros) or sends another user over 3000 € (three thousand Euros)
during a thirty (30) day period. Until step three verification is done the
withdraw, tip or deposit will be held. For step 3 a user/customer will be asked
for a source of wealth.
If not
provided in 30 days, the winnings will be canceled and account will be closed.
Customer identification and verification (KYC)
The formal identification of customers on entry into
commercial relations is a vital element, both for the regulations relating to
money laundering and for the KYC policy.
This identification relies on the following fundamental
principles:
A copy of your passport, ID card or driving license.
Also, we may request a second picture with the face of the user/customer.
Please note that all four corners of the ID have to be
visible in the same image and all details has to be clearly readable besides
the named above. We might ask for all details if necessary. An employee may do
additional checks if necessary, based on the situation.
Proof of Address:
Proof of address will be done via to different electronic
checks, which use two different databases. If an electronic test fails, the
user/customer has the option to make a manually proof. A recent utility bill
sent to your registered address, issued within the last 3 months or an official
document made by the government that proofs your state of residence.
To make the approval process as speedy as possible,
please make sure the document is sent with a clear resolution where all four
corners of the document is visible, and all text is readable.
For example: An electricity bill, water bill, bank
statement or any governmental post addressed to you. An employee may do
additional checks if necessary, based on the situation.
Source of funds
If a player deposits over a five thousand euro there is a
process of understandings the source of wealth (SOW)
Examples of SOW are:
·
Ownership of business
·
Employment
·
Inheritance
·
Investment
·
Family
It is critical that the origin and legitimacy of that
wealth is clearly understood. If this is not possible an employee may ask for
an additional document or prove.
The account will be frozen if the same user deposits
either this amount in one go or multiple transactions which amount to this. An
email will be sent to them manually to go through the above and an information
on the website itself.
betcoco.com also asks for a bank wire/credit card to
further insure the Identity of the user/customer. It also gives additional
information about the financial situation of the user/customer.
Basic document for step one:
The basic document will be accessible via the setting
page on [betcoco.com]. Every user has
to fill out the following information’s:
·
First name
·
Second name
·
Nationality
·
Gender
·
Date of Birth
The document will be saved and created by an AI, an
employee may do additional checks if necessary based on the situation.
Additional measurements.
In addition, an AI which is overseen by the AML
compliance officer will look for any unusual behaviour and report it right away
to a employee of betcoco.com.
According to a risk based few and general experience the
human employees will recheck all checks which are done bevor by the AI or other
employees and may redo or do additional checks according to the situation.
In addition, a data Scientist supported by modern,
electronic, analytic systems will look for unusual behaviour like: Depositing
and withdrawing without longer Betting sessions. Attempts to use a different
Bank account to for Deposit and Withdraw, nationality changes, currency
changes, behaviour and activity changes as well as checks, if an account is
used by its 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.
Politcally Exposed Persons (PEP) and Sanctions Policy
Within our AML policy, paramount consideration is granted
to the detection and management of transactions involving Politically Exposed
Persons (PEPs) and Sanctioned Individuals and Entities (SIECs). PEPs encompass
individuals occupying prominent public positions or wielding significant
influence, thereby amplifying the risk of financial misconduct or the misuse of
in-game assets. SIECs are individuals or entities that have been designated by
governments or international organizations as being involved in terrorist
financing, money laundering, or other financial crimes.
By seamlessly integrating PEP and sanctions screening
protocols into our AML framework, we are resolutely committed to thwarting any
attempts to exploit our virtual economy for purposes such as graft,
malfeasance, or the channeling of unlawful proceeds. Through continuous and
vigilant oversight, we are poised to expeditiously identify any potential
engagements with PEPs or SIECs and take decisive measures to fortify the
sanctity of our online casino environment. This proactive stance not only
mirrors our dedication to equitable and lucid gaming practices but also
underscores our unwavering resolve to uphold ethical benchmarks within the
realm of virtual gaming.
Enhanced Due Diligence
As an integral facet of our AML strategy, Enhanced Due
Diligence (EDD) holds a pivotal role in our commitment to maintaining a secure
and transparent gaming environment. EDD is a meticulous process that
supplements standard due diligence procedures and is triggered in cases where
higher risk is detected, such as transactions involving high-value players,
complex financial structures, or jurisdictions with elevated AML risks. By
harnessing advanced technological tools and comprehensive data analysis, we
systematically assess and verify player identities, sources of funds, and
transaction patterns. This multi-faceted approach ensures that we have a
comprehensive understanding of our players' financial behaviors, allowing us to
promptly identify and address any unusual or potentially illicit activities.
Through the application of EDD, we not only fortify our defenses against money
laundering and fraudulent activities but also cultivate an atmosphere of trust,
integrity, and responsible gaming within our online casino platform.
Enterprise-wide risk assessment
As part of its risk-based approach, betcoco.com has conducted an
AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks
specific to betcoco.com and its business lines.
The AML risk policy is determined after identifying and
documenting the risks inherent to its business lines such as the services the
website offers. 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. The identification of AML risk categories is based on betcoco.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.
The EWRA is yearly reassessed.
Ongoing transaction monitoring
AML-Compliance ensures that an “ongoing transaction
monitoring” is conducted to detect transactions which are unusual or suspicious
compared to the customer profile.
This transaction monitoring is conducted on two levels:
1) The first Line of Control:
betcoco.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 betcoco.com from taking place without
proper execution of KYC procedures onto the potential customer.
2) The second Line of Control:
betcoco.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;
Also, the three-step verification with adjusted risk
management should provide all necessary information’s about all customers of betcoco.com at all time.
Also, all transaction must be overseen by employees over
watched by the AML compliance officer who is over watched by the general management.
The specific transactions submitted to the customer
support manager, possibly through their Compliance Manager must also be subject
to due diligence.
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.
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).
Any betcoco.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.
3) The third Line of Control:
As a last line of defense against AML betcoco.com will do manually
checks on all suspicious and higher risk users in order to fully prevent money
laundering.
If fraud or Money Laundering is found the authorities
will be informed.
Reporting of Suspicious transactions on betcoco.com
In its internal procedures, betcoco.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. Reports of atypical transactions
are analyzed within the AML team in accordance with the precise methodology
fully described in the internal procedures.
Depending on the result of this examination and based on
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 it is necessary to terminate the
business relations with the customer.
Procedures
The AML rules, including minimum KYC standards will be
translated into operational guidance or procedures that are available on the
Intranet site of betcoco.com.
Record keeping
Records of data obtained for the purpose of
identification must be kept for at least ten years after the business
relationship has ended.
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. This data will be safely, encrypted stored offline and
online.
Training:
betcoco.com human employees will make manual controls on
a risk-based approve for which they get special training.
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. 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 in Coco Loco Holdings NV AML team.
Auditing
Internal audit regularly establishes missions and reports
about AML activities.
Data Security:
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.
betcoco.com will follow all guidelines and rules of the
data protection directive (officially Directive
95/46/EC)
Contact us:
If you have any questions about our AML and KYC Policy,
please contact us:
By email: support@betcoco.com
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 email: support@betcoco.com
