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Anti-Money Laundering and Counter-Terrorism Financing Policy
The purpose of this Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) policy is to identify and assess the risks of money-laundering (ML) and terrorism financing (TF) to which Evo (the Operator) may be subject, and outline the policies, controls and procedures in place to control and mitigate the identified risks. It ensures compliance with the Tobique Gaming Commission’s regulations concerning AML and CTF, and relevant national and international regulations.
Risk Assessment
Definitions: for the purposes of preparing this risk assessment, the following definitions are adopted, based on the FATF risk assessment methodology:
“Risk” is perceived as a function of three factors: threats, vulnerabilities, and consequences.
“Threat” is an individual, group or action that has the possibility (potential) to damage the state, society, economy or the organization. The threat is the starting point of the risk assessment.
“Vulnerability” represents those weaknesses that can be exploited by the threat to commit ML/TF actions through gambling activity.
“Risk factors” means variabilities that, individually or in combination, may increase or decrease the ML/TF risk arising or likely to arise from a random operation or transaction.
“Consequences” means the impact or damage that ML/TF may cause to gambling, institutions or the economy as a whole.
In conducting this risk assessment we will take into account several ML and TF risk factors relating to our customers, the countries and geographical areas of operation, payments and transactions, and third parties.
The main threat to the operator is mainly related to attempts by individuals or members of organized criminal groups to launder money through gambling. In addition to that, a threat also exists from attempts of politically exposed persons (PEP) to launder money obtained from crime. There is a risk that an account may be opened using false information or by someone other than the registered individual for the purpose of carrying out ML/TF activity. Individuals subject to sanctions may attempt to open an account and transact with an online operator which represents a great risk of ML/TF. Customers who are unable to prove their source of funds can also be viewed as possessing high risk, as well as such customers that use many and different payment methods and/or attempt to create multiple accounts with the operator. The ownership of the payment methods can also be used to identify individuals attempting to launder money, as payment methods belonging to a different individual and corporate payment methods can be used to deposit criminally obtained funds.
Gambling is characterized by a large volume of transactions which naturally exposes the operator to ML/TF risks. Payments made through methods known for high anonymity or susceptibility to abuse, such as cash, prepaid cards, or anonymous electronic payments are considered as one of the main risks. Payment providers also pose risk to the operator in case they do not comply with AML controls or have weak AML compliance. In terms of transactions, such that deviate significantly from the customer’s usual behavior may point to a ML attempt, as well as transactions that cannot be easily explained or justified. There is a risk that a customer may deposit criminal funds into their account and then withdraw them without any gameplay or following minimal play, low-risk wagering activity.
Some countries and geographic areas post a higher risk of ML/TF than others. There is a risk that customers from countries which have been highlighted by sources such as FATF as having strategic AML/CTF deficiencies look to abuse the sector for ML/TF activity. There is also a risk when accepting customers from countries that have high levels of corruption as this increases the risk of ML taking place.
Third party providers are considered to also present a risk to the operator in terms of ML/TF. Those are providers with questionable AML/CTF practices, poor compliance history, or connections to high-risk jurisdictions.
Evo implements and maintains policies, controls and procedures as part of its obligations to mitigate and effectively manage the risks of ML and TF identified during the risk assessment process.
“Risk” is perceived as a function of three factors: threats, vulnerabilities, and consequences.
“Threat” is an individual, group or action that has the possibility (potential) to damage the state, society, economy or the organization. The threat is the starting point of the risk assessment.
“Vulnerability” represents those weaknesses that can be exploited by the threat to commit ML/TF actions through gambling activity.
“Risk factors” means variabilities that, individually or in combination, may increase or decrease the ML/TF risk arising or likely to arise from a random operation or transaction.
“Consequences” means the impact or damage that ML/TF may cause to gambling, institutions or the economy as a whole.
In conducting this risk assessment we will take into account several ML and TF risk factors relating to our customers, the countries and geographical areas of operation, payments and transactions, and third parties.
The main threat to the operator is mainly related to attempts by individuals or members of organized criminal groups to launder money through gambling. In addition to that, a threat also exists from attempts of politically exposed persons (PEP) to launder money obtained from crime. There is a risk that an account may be opened using false information or by someone other than the registered individual for the purpose of carrying out ML/TF activity. Individuals subject to sanctions may attempt to open an account and transact with an online operator which represents a great risk of ML/TF. Customers who are unable to prove their source of funds can also be viewed as possessing high risk, as well as such customers that use many and different payment methods and/or attempt to create multiple accounts with the operator. The ownership of the payment methods can also be used to identify individuals attempting to launder money, as payment methods belonging to a different individual and corporate payment methods can be used to deposit criminally obtained funds.
Gambling is characterized by a large volume of transactions which naturally exposes the operator to ML/TF risks. Payments made through methods known for high anonymity or susceptibility to abuse, such as cash, prepaid cards, or anonymous electronic payments are considered as one of the main risks. Payment providers also pose risk to the operator in case they do not comply with AML controls or have weak AML compliance. In terms of transactions, such that deviate significantly from the customer’s usual behavior may point to a ML attempt, as well as transactions that cannot be easily explained or justified. There is a risk that a customer may deposit criminal funds into their account and then withdraw them without any gameplay or following minimal play, low-risk wagering activity.
Some countries and geographic areas post a higher risk of ML/TF than others. There is a risk that customers from countries which have been highlighted by sources such as FATF as having strategic AML/CTF deficiencies look to abuse the sector for ML/TF activity. There is also a risk when accepting customers from countries that have high levels of corruption as this increases the risk of ML taking place.
Third party providers are considered to also present a risk to the operator in terms of ML/TF. Those are providers with questionable AML/CTF practices, poor compliance history, or connections to high-risk jurisdictions.
Evo implements and maintains policies, controls and procedures as part of its obligations to mitigate and effectively manage the risks of ML and TF identified during the risk assessment process.
Internal Controls
Evo has implemented customer due diligence (CDD) processes which are appropriate, proportionate to the nature and size of its business and tailored to its various business activities, and in compliance with the requirements as set out by the Tobique Gaming Commission. We carry out CDD on all our customers, as well as apply enhanced due diligence (EDD) for customers that post higher risk of ML and TF. Customers are also subject to ongoing monitoring for the duration of their relationship with Evo. There is also an established process for record keeping of all information obtained during the aforementioned processes. Evo also ensures that all its employees receive adequate AML/CFT training.
Customer Due Diligence
CDD measures are undertaken when a customer opens an account and Evo makes sure that the verification of identity is completed as soon as reasonably possible following the deposit of funds into the account. The CDD measures taken by the operator are as follows:
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Identification during the verification process consisting of the customer’s name, date of birth and physical address.-
Verification of the provided details and customer’s identity using reliable independent documents.-
Screening checks.Enhanced Due Diligence
The operator performs EDD checks on higher risk customers in an effort to mitigate any ML/TF risk that they might pose. Those checks are a necessary extra step in addition to the CDD and are applied:
The EDD measures include, apart from the information obtained during CDD, the following:
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Where the risk assessment of a customer has changed.-
Where there are suspicions regarding the true identity of the customer.-
When a customer makes transactions that deviate from his usual behavior.-
When there is a suspicion of ML/TF.-
For customers originating from high-risk countries or jurisdictions.-
For customers who have used stolen or fake identity.-
For customers that used high-risk payment methods.-
Whenever there is adverse media about the customer related to financial crimes and/or criminal offenses.-
For customers that have been identified as PEPs.-
For customers that have direct or indirect links to a sanctioned individual, institution or country.-
Whenever the activity of a customer exceeds his estimated affordability level.The EDD measures include, apart from the information obtained during CDD, the following:
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Additional information to identify the customer’s identity.-
Obtaining additional information on the customer’s source of funds and/or source of wealth.-
Enhanced customer screening.-
Enhanced ongoing monitoring.Politically Exposed Persons
Evo has in place appropriate controls, including risk-based procedures, to determine whether a customer is a politically exposed person (PEP) and to manage the enhanced risks arising from the relevant person's business relationship or transactions with such a customer. Those controls and procedures include:
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Checking the identity of customers against PEP, sanctions and enforcement lists. This function is provided electronically by an external third party provider.-
Where a potential or existing player is identified by electronic identification verification as a PEP, or as being on a sanctions list, the player details are sent to Evo’s AML department to confirm the match.-
EDD must be undertaken for any customer identified as a PEP, or potential PEP. In particular the source of any funds or wealth of the customer must be established.-
If a match is confirmed the account is placed under constant monitoring and sent to the MLRO for the continuance of the relationship approval.Ongoing Monitoring
All of Evo’s customers are subject to ongoing monitoring for the duration of their relationship with the operator. These ongoing monitoring includes the following:
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Regular customer screening against PEP, sanctions and adverse media databases.-
Monitoring of customer transactions with the aim to spot any deviations from the usual behavior of the customer.-
Monitoring the value, frequency and volume of the bets placed by the customer in order to determine if they match their estimated affordability level.-
Review of the existing records and with the aim to keep the customer documents and/or information up to date.-
Regular checking of the registrations with the aim to identify linked and/or duplicate accounts.Record Keeping
Evo will retain a copy of the documents and information necessary in order to comply with its regulatory obligations. All records on transactions, payments, copies of documents, account files and business correspondence will be kept for at least five years after the business relationship with the customer has ended.
Reporting
The operator has an obligation to and will comply with the Tobique Gaming Commission's requirement to report to the Commission any identified cases of suspicious activity where the operator knows of or reasonably suspects that certain customer behavior may be related to ML/TF.
Training of Employees
Evo will ensure that all its employees are aware of their obligations and responsibilities relating to ML and TF. All employees will undergo an annual training on AML and CTF and must demonstrate that they have understood their responsibilities, obligations and the requirements set out by this Policy.
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