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Victory Willbeours N.V.
RULES OF PROCEDURE FOR THE PREVENTION OF MONEY
LAUNDERING AND TERRORISM FINANCING AND THE
IMPLEMENTATION OF INTERNATIONAL FINANCIAL SANCTIONS
AND THE INTERNAL
CONTROL RULES FOR THEIR MONITORING

  1. General Provisions

    1. These rules of procedure for the prevention of money laundering and terrorist financing and the application of international financial sanctions and the internal control rules for the control of the fulfilment of these obligations (hereinafter internal rules) are to be observed and applied to all employees and managers of Victory Willbeours N.V., a company registered and established under the laws of Curaçao, with registration number 134627 and registered address at P.O. Box 3075, Curaçao, Willemstad, Heelsumstraat 51 E-Commerce Park (hereinafter Victory Willbeours N.V.). The internal rules apply to all business relationships and transactions with customers in Victory Willbeours N.V.'s business activities to prevent the establishment of business relationships and transactions with anonymous or unidentified persons and to ensure compliance with other statutory requirements for the prevention of money laundering and terrorist financing. In fulfilling the obligations arising from the internal rules, the information technology solutions used in Victory Willbeours N.V. shall be used under the conditions and in accordance with the procedure provided for that purpose.
    2. The leading role of these internal rules is to establish rules that Victory Willbeours N.V. would prevent the use of the financial system and economic space of the European Union for money laundering and terrorist financing.
    3. The internal rules are a document that sets out Victory Willbeours N.V.'s code of conduct for the prevention of money laundering and terrorist financing, i.e., inter alia, the basic principles and procedures for communication between Victory Willbeours N.V. and the customer and the general terms and conditions for transactions between Victory Willbeours N.V. and the customer.
    4. The internal rules shall ensure the proper identification and verification of the customer or the person involved in the transaction and his/her representative, the identification and verification, the purpose and nature of the business relationship and continuous monitoring of the business relationship, including monitoring of relevant transactions, updating of relevant documents, data or information and where applicable, identification of the source and origin of the funds used in the transaction.
    5. The internal rules shall be applied in conjunction with the relevant legislation and the instructions of competent authorities.
    6. Victory Willbeours N.V. conducts a risk assessment prior to the commencement of the service in order to understand the risks of money laundering and terrorist financing it may face and identifies the risk appetite. Victory Willbeours N.V. bases its risk assessment and identification of risk appetite on the requirements provided by law.
    7. In no case will Victory Willbeours N.V. provide the customer or a non-authorized Victory Willbeours N.V. employee with information regarding the notification made to the financial supervisory authorities (hereinafter financial supervisory authorities) or about the identification of the subject of the financial sanction.
    8. Victory Willbeours N.V. always intends to provide its services in the same way (internet solution) and to provide the same service to customers. Therefore, these internal rules do not analyze or specify procedures for assessing the risks associated with new products and services or the risks associated with new sales channels.
    9. Jiraleo Limited is owned by Victory Willbeours N.V. and belong to the same group of companies. Victory Willbeours N.V is regulated and holds a valid Curacao Gambling license number 8048/JAZ2015-009.
  2. Definitions

    1. Money laundering means: a) the conversion or transfer of property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s actions or b) the acquisition, possession or use of property derived from criminal activity or property obtained instead of such property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation therein or c) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such an activity. Money laundering also means participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the aforementioned activities.
    2. Business activity is the service provided by Victory Willbeours N.V. of gaming.
    3. Terrorism financing means the financing and supporting of an act of terrorism and commissioning thereof as well as making funds available or raising them, knowing that they may be used, in whole or in part, to commit an act of terrorism.
    4. Politically exposed person means a natural person who is or who has been entrusted with prominent public functions including a head of State, head of government, minister and deputy or assistant minister; a member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court, a member of a court of auditors or of the board of a central bank; an ambassador, a chargé d'affaires and a high-ranking officer in the armed forces; a member of an administrative, management or supervisory body of a State-owned enterprise; a director, deputy director and member of the board or equivalent function of an international organisation, except middle-ranking or more junior officials. As well as a family member of a politically exposed person - the spouse, or a person considered to be equivalent to a spouse, of a politically exposed person or local politically exposed person; a child and their spouse, or a person considered to be equivalent to a spouse, of a politically exposed person or local politically exposed person; a parent of a politically exposed person or local politically exposed person. As well as a person known to be a close associate of the politically exposed person - natural person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement, or any other close business relations, with a politically exposed person or a local politically exposed person; and a natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a politically exposed person or local politically exposed person.
    5. A contact person of the financial supervisory authorities is an employee appointed by the decision of the management board, who is the contact person of the financial supervisory authorities and regulates and controls the implementation of the measures established for the prevention of money laundering and terrorist financing. The contact person can only be a person who has the necessary education, professional suitability, necessary abilities, personal qualities and experience and an impeccable reputation to perform the duties of the contact person. Victory Willbeours N.V. shall ensure that the contact person has the necessary competence, resources and access to relevant information to perform the tasks set out in the Money Laundering and Terrorist Financing Prevention legislation.
    6. Money Laundering and Terrorist Financing Prevention legislation is a law governing Victory Willbeours N.V. 's activities in the field of money laundering and terrorist financing. In the event of any conflict with these internal rules, the requirements set out in the Money Laundering and Terrorist Financing Prevention legislation shall apply.
  3. General Application of Due Diligence Measures

    1. The purpose of persons involved in money laundering and terrorist financing is to conceal their identity, the origin of the funds and the real purpose of the transactions. In order to prevent money laundering or terrorist financing through Victory Willbeours N.V., Victory Willbeours N.V. (for the purposes of these internal rules, Victory Willbeours N.V. shall always mean all Victory Willbeours N.V. directors and employees whose duties are establishing business relationships or entering into transactions) shall apply the due diligence measures set forth in these internal rules and report money laundering or terrorist financing or similar activities. These measures are aimed at making it clear to Victory Willbeours N.V. directors and employees at all times who is entering into legal relationships and with whom and the origin of the funds of the financial transactions.
    2. Victory Willbeours N.V. has established a clear methodology for applying due diligence measures in line with the company's structure and volume of operations. The methodology is introduced to all employees both when starting work and regularly during the employment relationship. Victory Willbeours N.V. is also obliged to organize the training of the responsible employees of all cooperation partners on the basis of these rules of procedure and in accordance with the transfer of activities. The training shall be organized as necessary, especially in the event of significant changes to these rules. The training must provide, inter alia, information on the obligations laid down in the rules of procedure, the modern methods and risks involved in committing money laundering and terrorist financing, the requirements for the protection of personal data, how to identify possible money laundering or terrorist financing operations and how to deal with such situations.
    3. Victory Willbeours N.V. directors and employees must pay close attention to the customer’s activities and circumstances that indicate or are likely to be involved in money laundering or terrorist financing, including complex, high-value and unusual transactions and transaction patterns that do not have a reasonable or visible economic or legitimate purpose or which are not specific to a particular business. Increased attention is also paid to the business relationship if the customer comes from a high-risk third country or a country has the citizenship or residence of that country or the payee's payment service provider is located in that country or territory.
    4. The customer must confirm and agree that it uses the services provided by Victory Willbeours N.V. only for the provided purpose and intended use. The customer must always be ready to explain the purpose of the transaction and the source and origin of the funds used for it. During the business relationship, Victory Willbeours N.V. verifies, on the basis of the logs stored for the customer, whether the transactions performed by the customer have a reasonable economic purpose and compares the customer’s activities with its previous behavioral habits and previously known information about it. Victory Willbeours N.V. will determine whether the business relationship and the customers’ transactions are consistent with the customer’s normal participation in civil market and whether the business relationship and the transaction have a clear economic justification and whether the other conditions set out in section 3.3 of these guidelines are met.
    5. If the nature of the service provided by Victory Willbeours N.V., the restrictions set forth in section 1.8 of these guidelines and the high level of security of the information systems used by Victory Willbeours N.V. and customer controls reduce the risk of money laundering and terrorist financing, the business relationship between Victory Willbeours N.V. and the customer is established without being in the same place with the customer. Victory Willbeours N.V. applies due diligence measures to the extent appropriate to the business relationship, the nature of the transaction or the level of risk associated with the transaction. However, given the risk involved in providing the service in accordance with international typologies, Victory Willbeours N.V. does not assign a lower level of risk to its customers, so it does not apply simplified due diligence measures to any customer and has not defined such procedures in these internal rules.
    6. Victory Willbeours N.V. does not provide services to a person with whom it has not established a business relationship. No services are provided and no business relationship is established with anonymous persons, persons whose shares or units are bearer shares or shadow banks. Once a business relationship is established, the services are not provided to persons or in situations where:

      • a) a transaction is requested which has as its object the concealment of the actual parties to the transaction;
      • b) a transaction is requested which does not have a clear reasonable business, economic, tax or legal purpose;
      • c) for any reason, there is a suspicion that the customer or the transaction made by the customer may be related to money laundering or terrorist financing.
    7. Victory Willbeours N.V. undertakes to apply due diligence measures in any case in the following situations:

      • a) establishing a business relationship;
      • b) in case of suspicion of inadequacy or inaccuracy of documents or data previously collected in the course of identification and verification of the submitted information or updating of the relevant data.
      • c) in case of suspicion of money laundering or terrorist financing.
    8. Victory Willbeours N.V. does not apply to occasional transactions, because a business relationship must always be entered into when making a transaction.
    9. Due diligence measures must be applied before establishing a business relationship or concluding a transaction, if a corresponding exception or right is provided by law.
    10. Due diligence measures shall always be applied at least to the minimum extent (i.e. normal due diligence measures) within the meaning of section 5 of these internal rules and in the event of higher than normal risk (i.e. high risk) within the meaning of section 7 of these internal rules.
    11. Victory Willbeours N.V. shall immediately notify the financial supervisory authorities of any suspicion of money laundering or terrorist financing, in full compliance with the confidentiality obligation specified in section 11.5 of these guidelines.
    12. In order to enter into a customer agreement, the customer fills in a form in which it is asked to submit the main mandatory data necessary for the application of due diligence measures and required by legislation. The customer confirms the accuracy of the submitted data with a signature and confirms that the submission of false data may involve both civil and criminal liability. Victory Willbeours N.V. saves the completed and signed form in the customer's file, the data being stored in accordance with the procedure set out in section 9 of these guidelines.
  4. Assessing the risk of money laundering and terrorist financing and determining the scope of due diligence measures

    1. Victory Willbeours N.V. must assess the risk and level of money laundering and terrorist financing and, with this in mind, select and implement appropriate due diligence measures.
    2. Victory Willbeours N.V. has exercised due diligence measures adequately if Victory Willbeours N.V. emerges from its best understanding, not biased by other interests of itself, its customers or third parties, that it has complied with its due diligence.
    3. The level of risk of money laundering and terrorist financing is assessed taking into account three categories of risks: geographical, customer and transaction risk.
    4. The geographical risk is considered high and thus the customer's risk is high if the customer or transaction has a known connection with countries or territories referred to in section 3.3 of these internal rules that are considered low-tax or established by the FATF in the list of non-cooperating or high-risk countries.
    5. The customer's risk is considered high, in addition to appearance of geographical risk, also if the customer is a politically exposed person, the customer who is a natural person has someone else as the real beneficiary, the customer is suspected of being under financial sanctions. If a customer is known or suspected to be involved in money laundering or terrorist financing, Victory Willbeours N.V. will not establish or continue a business relationship with the customer.
    6. A customer's risk is considered high if the customer's activities may refer to servicing other customers, which activities require a license, the customer is engaged in holding personal assets, the customer's activities are largely cash-intensive, the customer is in the precious stones or metals business, the customer is in the lottery or casino business.
    7. In determining the customer's risk level and in determining the risks on the basis of sections

      4.4 to 4.6 of these guidelines, Victory Willbeours N.V. also takes into account the guidelines of the European Banking Authority on risk factors.
    8. As a result of the assessment, Victory Willbeours N.V. determines the risk profile of the person involved in the business relationship or transaction: normal or high. In accordance with section 3.5 of these internal rules, no customer risk is considered to be low, so that due diligence measures are in no case applied in a simplified manner.
    9. If the customer or transaction reveals at least one of the risk factors specified in sections 4.4- 4.6 (incl.), the customer shall be subject to enhanced due diligence measures and a high level of risk shall be assigned to the customer.
    10. Victory Willbeours N.V. refuses to provide the service to the customer and interrupts the completion of the service if the customer does not disclose all the information required by Victory Willbeours N.V. or provides it in incomplete form. In this case, Victory Willbeours N.V. may request complete information about the customer. If, despite a request to that effect, the customer does not provide the necessary information, Victory Willbeours N.V. will refuse to enter into the respective transaction and will inform the financial supervisory authorities.
  5. Minimum due diligence measures to be applied in establishing a business relationship (i.e. due diligence measures to be applied in a normal situation and in the case of medium risk)

    1. Victory Willbeours N.V. shall, as a minimum, apply the following due diligence measures when establishing a business relationship:
      • a) identification of a customer and verification of the submitted information based on information obtained from a reliable and independent source. Reliable and independent sources are documents prepared by the person or its representative; identity documents; documents submitted by the person itself; national registers and other public databases; reliable and independent private databases; data of the European Union and other recognized international organizations and on their websites; data available from search engines (assessing the source and its compiler); information published by state and supervisory authorities; other data that Victory Willbeours N.V. considers to be reliable and independent in its internal belief;
      • b) identification and verification of the identity and right of representation of the representative of a natural or legal person;
      • c) understanding the business relationship and operation and, where appropriate, gathering additional information about it.
    2. For identification, Victory Willbeours N.V. collects in case of a customer who is a natural person:
      • a) name;
      • b) personal identification code or date and place of birth;
      • c) profession or activity;
      • d) place of residence or seat, and Victory Willbeours N.V. uses two sources for identification, which may be an identity document, a device enabling strong authentication (e.g. ID card, mobile ID, etc.), a payment made to an account opened by a person with a credit or payment institution, an extract from the population register, a utility or other bill certifying the residence or location of the person in the place referred to, a document certifying the pursuit of a professional or trade activity, other information obtained from a reliable and independent source.
    3. Victory Willbeours N.V. collects and stores the following information about the transaction: the date or period of the transaction; a description of the content of the transaction; the amount of the transaction; the currency of the transaction; bank account numbers.
    4. The purpose of the business relationship is normally derived from Victory Willbeours N.V.'s business activities. Where appropriate, Victory Willbeours N.V. collects additional information.
    5. When applying due diligence measures, the facts to be established are generally determined on the basis of the original documents submitted by the customer or copies made of them (scanned version of the original). If the original document cannot be obtained, documents certified or authenticated by a notary or officially may be used. If this is not practicable given the level of risk, a copy of the original document must be stamped and/or signed by the issuer and may be forwarded electronically (in written reproducible form). The copy may not be relied upon if there is any doubt as to its conformity with the original.
    6. The application of due diligence measures may also be based on information obtained in a form that can be reproduced in writing from a credit institution or a branch of a foreign credit institution registered or established in a contracting state of the European Economic Area or in a third country with requirements equivalent to Money Laundering legislation.
    7. In case of identification by video, Victory Willbeours N.V. complies with the Money Laundering legislation and shall make available to the public on its website the information and verification of identity provided for in that regulation by means of information technology. Identification and the successful completion of the data verification process do not oblige Victory Willbeours N.V. to establish a customer relationship or ensure the availability of services. Victory Willbeours N.V. has the right to choose with whom it establishes a customer relationship and with whom it does not.
    8. Victory Willbeours N.V. uses high-reliability technology for the identification and verification of information by means of information technology, which ensure reliable identification and prevent the alteration or misuse of the data transmitted. Victory Willbeours N.V. identifies the customer's real name and identity and makes sure that the aforementioned person does not use an unfamiliar identity.
    9. Victory Willbeours N.V. uses means of information technology that allows to record and reproduce the identification and verification procedure. Victory Willbeours N.V. uses means of information technology for identification that has the hardware and software required for digital identification of biometric data and allows for the comparison of biometric data. The video must be of sufficient quality, i.e. sufficient, clear and of high quality, to enable the person to be identified and verified.
    10. Suspicious users whose accounts have been blocked must undergo video verification. For the purpose of video identification and data verification, the identifiable person needs the following identity documents and means, and the procedures must comply with the following:
      • a) an ID card with valid certificates or another e-identification document with a high level of trust, which is entered in the list of the e-identification system of the European Union with a high level of trust;
      • b) a foreign national needs, in addition to the document specified in sub-clause a) of this section, a travel document issued abroad;
      • c) a foreign national needs, in addition to the document specified in sub-clause a) of this section, a travel document issued abroad;
      • d) hardware and software for digital identification of biometric data;
      • e) internet connection, webcam and microphone. The identification session must be permanent. The person must not leave the frame or the camera's field of view during the session.
      • f) a web browser.
    11. Identification and verification of data takes place in the following steps:
      1. Victory Willbeours N.V. identifies the person by an identity document that allows digital identification, with which the person logs into the Victory Willbeours N.V. e- environment.
      2. After successful identification, the person provides the legal confirmations necessary to continue the session and fills in the questionnaire and digitally signs it.
      3. Video verification is used when an account is blocked. After successful video verification, the user's account can be unlocked.
      4. Victory Willbeours N.V. conducts a real-time interview with the person, during which Victory Willbeours N.V. fulfils the feeling-own-customer principle and finds out the circumstances of establishing a customer relationship. During the interview, Victory Willbeours N.V., based on the answers to the questionnaire, asks the person for verification questions to verify or clarify the personal data and, if necessary, asks for additional information to clarify the person's risk profile. The Victory Willbeours N.V. employee is obliged to assess the person's reaction during the interview, the reliability of the information and data received and the consistency with the information or data obtained during other procedures, and to reflect both the assessment and the underlying circumstances in the customer profile. If it is not possible to communicate with the person in an intelligible manner or if there are other circumstances that prevent the interview from being conducted, the service provider must interrupt this procedure.
    12. If a situation specified in section 15.6 occurs, Victory Willbeours N.V. forwards a notification to the financial supervisory authorities.
    13. Requirements for image and sound recording stream (video) and data collected by video:
      1. the stream containing the image and sound is recorded in such a way that it can be reproduced with the same quality as the originally transmitted synchronized sound and image;
      2. the stream containing the image and sound is stored together with a time stamp, the customer's IP address, identifiable person, identifiable person's personal identification code, in the absence of a personal identification code, date and place of birth and country of residence, by the way the timestamp being linked to the data relating to it in such a way that any subsequent change, the person making the change, the time, the manner and the reason for it are identifiable;
      3. the picture and sound quality of the interview session must allow to communicate with the person establishing the business relationship, which is why Victory Willbeours N.V. evaluates the picture and sound quality of the customer's information technology equipment separately. The place where the person is must be well lit and the speech must not be disturbed acoustically (echo, background noise). It is important that the understanding of speech is not disturbed. The stream transmitting sound and images must be of sufficient quality to ensure that the person's face can be seen and unambiguously identified, and the person's head and shoulders must be visible and framed. The technological solution must transmit a color image with clear sound and ensure reproducible recording. The sound and image must be synchronous and reproducible without noticeable delay. In addition, the appearance, facial expressions and gestures of the person concerned must be clearly visible. The speech must always be easy to understand. The sound quality must be even and without external interference. The lighting should be in a way that the facial expression is always easily distinguishable, so that there is no shadow around the eyes and the screen does not shine against it. Victory Willbeours N.V. may provide instructions for changing the body position of a person and for placing the person and the document in a frame so that the identity of the person can be identified and verified, including viewing the data or images on the document. Victory Willbeours N.V. has the right to demand the removal of the head or face cover and glasses or to comply with the instructions provided by it to ensure identification and verification;
      4. Based on the interview, Victory Willbeours N.V. determines the customer profile, collects information and data and verifies it. During the interview, Victory Willbeours N.V. asks the person structured questions based on the results of the questionnaire. With the permission of Victory Willbeours N.V., a natural person or a legal representative of a legal entity may use the assistance of another person to resolve technical problems that have arisen during the interview. Victory Willbeours N.V. is obliged to assess the response of the person during the interview, the reliability of the information and data obtained and the consistency with the information or data obtained by other procedures, and to reflect both the assessment and the underlying circumstances in the customer’s and risk profile.
      5. Victory Willbeours N.V. records the data collected through the video and questionnaire and the following procedures:
      6. dentification;
      7. unsuccessful identification and data verification;
      8. real-time interview.
      9. Video recording begins with identification and ends when the data specified in section
      10. has been collected and the procedures have been performed.
      11. Victory Willbeours N.V. shall record each video meeting and retain those recordings and the accompanying data (including computerized identification information) in a format that can be reproduced for at least five years, unless a longer period is provided for by law.
    14. The fulfilment of the preconditions for identification and verification and the questionnaire are carried out by a Victory Willbeours N.V. employee, the corresponding automated system or, in the case of outsourcing, the person to whom the activity was transferred. Victory Willbeours N.V. is taking steps to avoid the risks of manipulating an automated system.
    15. When compiling and conducting the questionnaire and interview (asking questions from the customer) Victory Willbeours N.V. takes into account the following principles:
      1. finds out the address of residence of the natural person, activity profile, field of activity, purpose and nature of establishing business relationship, estimated volumes of services used by the person, as well as whether it is a politically exposed person and other relevant information;
      2. Victory Willbeours N.V. is obliged to evaluate the answers to the questionnaire and to reflect both the assessment and the underlying circumstances in the customer and risk profile.
    16. Victory Willbeours N.V. will compile a customer profile and, as part of it, a risk profile based on the systematic collection, analysis and clarification of data collected through the use of these rules of procedure and information technology tools, questionnaires, interviews and other available information. The customer and risk profile are compiled by Victory Willbeours N.V. in a form that can be reproduced in writing. Victory Willbeours N.V. evaluates the data collected through the procedures performed using the information technology tools and decides whether to establish a business relationship with the person or what the next regime of monitoring the business relationship with the customer will be.
    17. Victory Willbeours N.V. shall update the data collected during the questionnaire and interview in accordance with the requirements set forth in section 6.8 of these internal rules.
    18. Within that framework, Suspicious Activity Reports (SARs) are an imposed requirement. Victory Willbeours N.V. ensures that any employee reports to the Risk Team where they have grounds for knowledge or suspicion that a person or customer is engaged in ML or terrorist financing.
    19. Escalations of SARs should be done in a confidential, discreet manner, in a handwritten form and not via email so as to ensure maximum anonymity.
    20. Suspicious Activity comprises of many elements, examples of which are as follows:
    21. A low spend customer or a customer with a low income begins to spend more than their income;
    22. Stakes, wagered by the customer become unusually high or out of the ordinary;
    23. A customer exhibits unusual gambling patterns with an almost guaranteed return or very little financial risk;
    24. Money is deposited by a customer or held over a period and withdrawn by the customer without being used for gambling;
    25. A customer regularly gambles large amounts of money and appears to find a level of losses acceptable;
    26. A customer spend increases over a period of time, thereby making high spend and potential money laundering;
    27. A customer displays gambling patterns where spend is high but the risk is low, for example, gambling on red and black in roulette. The customer could be laundering money in a way that guarantees a minimal loss.
  6. Minimum due diligence measures applied during a business relationship (i.e. due diligence measures applied in a normal situation and in the case of medium risk)

    1. Victory Willbeours N.V. shall, as a minimum, apply the following due diligence measures during a business relationship:
      • a) continuous screening and monitoring of the customer's business relationship, including monitoring of transactions performed during the business relationship;
      • b) updating relevant documents, data and information; and
      • c) where applicable, identification of the source and origin of the funds used in the transaction.
    2. Victory Willbeours N.V. evaluates the customer's activities on the basis of the data collected about it and determines whether the information previously known about the customer corresponds to the customer's actual activities. All transactions, operations and related information performed by the customer in the Victory Willbeours N.V. electronic environment are stored in the Victory Willbeours N.V. information system.
    3. Victory Willbeours N.V. compares the customer data with publicly available data to determine whether the customer data matches the data published in the list of persons subject to an international sanction or whose residence is in the list of higher risk countries. Victory Willbeours N.V. also regularly compares the data with its own list, where Victory Willbeours N.V. keeps records of customers in respect of whom there has been any previous suspicion, as well as more frequent fraudulent schemes and situations suggesting money laundering and terrorist financing (including the financial supervisory authorities’ guidelines on money laundering or terrorist financing).
    4. Due diligence measures shall be applied throughout the business relationship inter alia in the following cases:
      • a) Victory Willbeours N.V. has doubts about the accuracy or inadequacy of the information collected during establishing a business relationship, as well as when the other party's activity is not normal (both in view of its own past behavior patterns or reasonable judgment) or transparent, and if Victory Willbeours N.V. suspects money laundering or terrorist financing;
      • b) it is an unusually large transaction or unusual transaction schemes of which the economic purpose remains questionable;
      • c) otherwise, if it is clear to Victory Willbeours N.V. that the information known about the customer does not correspond to the customer's actual activities.
    5. Victory Willbeours N.V. must continuously screen (observe in real time) and monitor (retrospectively evaluate) customer activity and assess changes in customer activity. Screening is performed using Victory Willbeours N.V. information technology equipment and monitoring is performed at the end of the month on the basis of predefined parameters, where Victory Willbeours N.V. screens the customers who have made the largest turnovers and the largest single transactions. Victory Willbeours N.V. shall also ensure on an ongoing basis that funds debited to the account for the exchange of virtual currency do not originate or are not transferred to the countries referred to in section 3.3 of these internal rules and shall take appropriate measures to suspend payments and notify the financial supervisory authorities.
    6. If Victory Willbeours N.V., including the contact person of the financial supervisory authorities, suspects that the customer's activities may be money laundering or terrorist financing or other illegal activities, it shall suspend the relevant transaction and notify the financial supervisory authorities or continue the execution of the transaction upon receipt of an order from the financial supervisory authorities.
    7. If a customer executes an unusual transaction compared to previously known transactions or a transaction based on unusual circumstances for which it is not known what the source and origin of the funds used in the transaction are, Victory Willbeours N.V. requests information from the customer about the source and origin of the funds used in the transaction. The source and origin of the transaction must also be identified if the value of the transaction performed by the customer does not coincide with the previous information about the customer (the customer's capabilities) or if it is a high value transaction for Victory Willbeours N.V..
    8. Victory Willbeours N.V. updates the data collected during the application of due diligence measures once a year for high-risk customers and in other cases every three years. If the customer does not actively execute transactions during this period, the data will be updated when the customer starts executing transactions again. Upon expiry of this deadline, Victory Willbeours N.V. will request confirmation of the correctness of the aforementioned data or submission of updated data. If, at the time of updating, the data used for identity verification, in particular the identity document, has become invalid, Victory Willbeours N.V. will also request a copy of the new compliant identity document.
    9. When establishing a business relationship with a customer and providing services during a business relationship, Victory Willbeours N.V. stores and maintains the customer's IP addresses. Based on them, it is possible to monitor the customer's location and compare the accuracy of the relevant information provided by the customer. If the information published by the customer does not match the identified IP addresses or the customer uses a changing IP address, Victory Willbeours N.V. will apply additional due diligence measures to the customer to determine the reason for the discrepancy or action and, if necessary, notify the financial supervisory authorities.
    10. To analyses the customer's transactions, Victory Willbeours N.V. uses an information system that allows highlighting transactions based on predefined parameters. The parameters are determined by the decision of the management board.
    11. Upon net deposits of EUR 25,000 in total or EUR 10,000 in one-month customers must go through a mandatory due diligence check or DDC.
    12. Enquiries are made into the source of customer deposits; all customers are requested to submit proof of income to substantiate customer responses. Proof of income may include Bank Statements, Pay Slips, Tax Bills, and/or any other valid proof of income.
    13. A risk assessment is then carried out to ensure there is no discrepancy between the customer’s income and the number of deposits the customer is making.
    14. Using open-source information and proof of income an estimate of the customer’s net worth is made. To do this Victory Willbeours N.V. assesses the estimated Net worth of the customer’s monthly salary, any additional funds, and property value whilst deducting estimated outgoings and compares this sum to customer losses.
    15. If suspicious transactions are discovered or if losses are greater than Net worth, then the AML officer is informed and they create a SAR and submit it to the relevant authority.
    16. Customers that pass the due diligence are permitted to continue to deposit at the casino. Additional due diligence checks are carried out when the customer deposits a further EUR 25,000 net or EUR 10,000 net in one-month, Victory Willbeours N.V. retains the right to carry out an additional due diligence check should they see fit.
    17. As a matter of course Victory Willbeours N.V. also carries out ongoing monitoring of account activity to assess conformity with customer expectations and to detect unusual activity which might be an “irregular transaction” or “irregular gaming activity” as well as spot checks on accounts to ensure procedures are being conformed to.
  7. Application of Enhanced Due Diligence Measures

    1. Victory Willbeours N.V. will apply enhanced due diligence measures in situations and circumstances involving a higher than usual risk of money laundering and terrorist financing (in particular, the cases referred to in sections 4.4 to 4.6 (inclusive) of these internal rules).
    2. In order to apply enhanced due diligence measures, Victory Willbeours N.V. shall implement, in addition to the minimum due diligence measures set forth in sections 5 or 6 of these internal rules, at least one of the following enhanced due diligence measures (depending on whether the transaction involves a higher risk of establishing or monitoring a business relationship):
      • a) verification of information additionally submitted upon identification of the person based on additional documents, data or information originating from a credible and independent source;
      • b) gathering additional information on the purpose and nature of the business relationship, transaction or operation and verifying the submitted information based on additional documents, data or information that originates from a reliable and independent source;
      • c) gathering additional information and documents regarding the actual execution of transactions made in the business relationship in order to rule out the ostensibility of the transactions;
      • d) gathering additional information and documents for the purpose of identifying the source and origin of the funds used in a transaction made in the business relationship in order to rule out the ostensibility of the transactions;
      • e) taking additional measures to verify the authenticity of the documents submitted and the accuracy of the information contained therein;
      • f) the making of the first payment related to a transaction via an account that has been opened in the name of the person or customer participating in the transaction in a credit institution registered or having its place of business in a contracting state of the European Economic Area or in a country where requirements equal to those of Directive (EU) 2015/849 of the European Parliament and of the Council are in force.
    3. Upon application of enhanced due diligence measures, the obliged entity must apply the monitoring of a business relationship more frequently than usually, including reassess the customer’s risk profile not later than six months after the establishment of the business relationship.
    4. In selecting enhanced due diligence measures, Victory Willbeours N.V. is guided by the need to mitigate the risk associated with a higher risk factor or factor.
    5. When Victory Willbeours N.V. establishes a business relationship with a politically exposed person (and this fact is established by Victory Willbeours N.V. by asking the customer a question, as well as by comparing the customer's profession and field of activity with positions of politically exposed persons), Victory Willbeours N.V. applies minimum and enhanced due diligence measures to the politically exposed person and his/her transactions. As enhanced due diligence measures, Victory Willbeours N.V. applies the following due diligence measures to a politically exposed person and to transactions made by him or her:
      • a) obtains approval from the senior management to establish or continue a business relationship with the person;
      • b) applies measures to establish the origin of the wealth of the person and the sources of the funds that are used in the business relationship or upon making occasional transactions;
      • c) monitors the business relationship in an enhanced manner.
    6. Victory Willbeours N.V. will also apply the enhanced due diligence measures set out in the European Bank Authority's own guidelines on risk factors.
    7. Victory Willbeours N.V. uses its internal software for PEP and sanctioned person screening, anti money laundering and anti-terrorism financing transaction monitoring. The Risk and Analytics Department is responsible for the monitoring.
  8. Impossibility of establishing a business relationship, refusal to enter into a transaction and extraordinary cancellation of the business relationship

    1. Victory Willbeours N.V. shall not establish a business relationship if it is unable to apply the due diligence measures set out in section 5 of these internal rules or if it suspects money laundering or terrorist financing.
    2. Victory Willbeours N.V. will extraordinarily cancel a business relationship if it is unable to apply due diligence measures during the business relationship or if the customer refuses to provide the information or documents necessary to implement the due diligence measures.
    3. If the circumstances specified in section 8.2 of these internal rules occur, Victory Willbeours N.V. shall not enter into any transaction with the customer.
    4. If there is a suspicion of money laundering or terrorist financing, in addition to notifying the financial supervisory authorities, Victory Willbeours N.V., after consulting the financial supervisory authorities, will seek additional information from the customer (without reference to the suspicion of money laundering or terrorist financing or reporting to the financial supervisory authorities) and in a situation where Victory Willbeours N.V. cannot overcome the suspicion due to the impossibility of applying due diligence measures, it also cancels the business relationship extraordinary due to the impossibility of applying due diligence measures.
    5. The prohibition on establishing a business relationship referred to in this section shall not apply if Victory Willbeours N.V. receives instructions to that effect from the financial supervisory authorities.
    6. In the event of an extraordinary cancellation of the business relationship, Victory Willbeours N.V. shall transfer the customer’s assets only to an account opened with a registered credit institution or a branch of a foreign credit institution or a credit institution registered or domiciled in a European Economic Area contracting state or in a country where requirements equivalent to those of Directive (EU) 2015/849 of the European Parliament and of the Council apply. In exceptional cases, the assets may be transferred to an account other than the customer's account by notifying the financial supervisory authorities at least seven business days in advance and provided that the financial supervisory authorities do not give a different instruction.
    7. Suspicious Activity in this case is being referred to as suspicious transactions, extreme player profiles, when deposits are not matching up amongst other elements. Other concrete examples of how we identify players who require our team to undertake a risk monitoring approach of our customers and when to specifically carry out enhanced due diligence checks on the Player Profiles can be further required.
    8. Victory Willbeours N.V. reviews players spend and gameplay to check for suspicious activity. Before any withdrawal is processed the following procedures are carried out:
    9. The customer's deposit history is reviewed to confirm that no suspicious payments have been made to the customer’s account. The frequency of deposits and the sum of deposits are reviewed to ensure they are within the normal range for the customers. If there are abnormalities in the deposit history, then the account is forwarded to the Risk Manager and an internal SAR is raised.
    10. The customer’s turnover is reviewed to ensure that they have played in the casino and are not using www.azino777.com as a method to move money. The www.azino777.com expects customers to wager a minimum of two times the deposit amount before a withdrawal. All accounts that do not meet this requirement are flagged and the reason for the customer’s withdrawal request is analyzed before funds being released.
    11. All funds must be refunded back to the original deposit method and it is forbidden for customers to share payment methods or to use payment methods belonging to other people. If the original payment method has been cancelled or lost the customer must submit proof the payment method has been cancelled. The customer’s funds will then be remitted to a valid bank account in the customer’s s name. If it is discovered that customers are sharing payment methods, then their accounts are blocked and an internal and external SAR is sent.
    12. If due to technical restraints www.azino777.com cannot remit funds to the original deposit method the funds will be sent to a valid bank account owned by the customer.
  9. Data Retention

    1. Victory Willbeours N.V. retains data related to the transaction for five years after the transaction and data collected during the establishment and monitoring of the business relationship for up to five years after the termination of the business relationship. The original accounting documents shall be kept by Victory Willbeours N.V. for the period prescribed by the law.
    2. Victory Willbeours N.V. shall retain all correspondence with the customer for up to five years after the termination of the business relationship, as well as details of suspicious or unusual transactions or circumstances that were not reported to the financial supervisory authorities and the circumstances and information on the basis of which the business relationship is refused and the business relationship is extraordinary cancelled in accordance with section 8 of these internal rules.
    3. Victory Willbeours N.V. shall retain notifications to the financial supervisory authorities for up to five years after the notification.
    4. Victory Willbeours N.V. shall store data in a manner that allows for an exhaustive and prompt response to inquiries from the financial supervisory authorities or other supervisory authorities, investigative bodies or courts in accordance with the law, inter alia, whether Victory Willbeours N.V. has or has had a business relationship with the person named in the request during the past five years and what the nature of that relationship is or was.
    5. If Victory Willbeours N.V. makes a request for identification to a database belonging to the national information system, the obligation to retain data shall be deemed to be fulfilled if the information on making an electronic request to the said register can be reproduced within five years after the termination of the business relationship or conclusion of the transaction.
    6. Victory Willbeours N.V. shall delete retained data after the expiry of the time limits, unless otherwise provided by the relevant legislation. At the request of the competent supervisory authority, data relevant to the prevention, detection or investigation of money laundering or terrorist financing may be kept at the request of that authority for longer, but not more than five years, after the expiry of the initial period.
  10. Contact person

    1. Victory Willbeours N.V.'s contact persons are Oleksandr Plakhtii (director) and Katerina Novak (AML and Regulatory Compliance Officer) a supervisory official who are responsible for informing the financial supervisory authorities and enforcing precepts and international financial sanctions.
    2. The tasks of the contact person are:
      • a) organizing and analyzing the collection of information referring to unusual or suspected money laundering transactions or terrorist financing arising from Victory Willbeours N.V. activities;
      • b) communication with the financial supervisory authorities, i.e. in case of suspicion of money laundering or terrorist financing, forwarding information to the financial supervisory authorities and responding to the inquiries submitted by the financial supervisory authorities and complying with precepts;
      • c) submitting written reviews once a year to other members of the management board, including informing about deficiencies in compliance with this procedure, instructions of supervisory and investigative authorities and legislation;
      • d) verification of compliance with anti-money laundering requirements (performance of internal control tasks within the meaning of section 13 of these internal rules);
      • e) ensure the maintenance of technical equipment and documentation necessary for the prevention of money laundering and terrorist financing;
      • f) to inform the employees of Victory Willbeours N.V. as soon as possible and clearly of any problems related to the implementation of this procedure.
    3. The contact person shall also be responsible for ensuring the implementation of the international financial sanction provided for in section 13 of these internal rules and for assuming the other obligations set out in this section.
    4. The contact person shall have the right to:
      • a) make proposals for the amendment and supplementation of this procedure and for the organization of regular training on compliance with the requirements arising from law for the employees of Victory Willbeours N.V., whose duties include the establishment of business relations or the conclusion of transactions;
      • b) require the Victory Willbeours N.V. unit to remedy the shortcomings identified in complying with the anti-money laundering and anti-terrorist financing requirements within a reasonable time;
      • c) monitor the activities of Victory Willbeours N.V. employees in compliance with this procedure and related legislation, including to read the e-mail exchange on the employees' work computer, to participate from time to time in the performance of the duties of the Victory Willbeours N.V. employee and to check the documents prepared by the employee;
      • d) demand compliance with the requirements set out in this procedure and the immediate termination of the violation thereof if the circumstances of the violation of the requirements have become clear;
      • e) interview Victory Willbeours N.V. employees in connection with the analysis of data obtained in the course of their activities;
      • f) conduct trainings and tests from time to time, the purpose of which is to check the knowledge of the employee in connection with the provisions of this procedure;
      • g) make proposals for the organization of the process for submitting suspicious and unusual notifications;
      • h) receive training in the field.
    5. The contact person must respect the privacy of employees in the performance of their duties.
    6. The contact person may forward information or data which has become known to him or her on suspicion of money laundering only to the management board, the financial supervisory authorities, the pre-trial investigation authority in connection with criminal proceedings and the court on the basis of a court order or decision.
    7. Contact email: victorywillbeours@novomats.net.
  11. Notification of the financial supervisory authorities

    1. Victory Willbeours N.V. shall notify the financial supervisory authorities if it identifies in economic or professional activities, a professional act or provision of a professional service an activity or facts whose characteristics refer to the use of criminal proceeds or terrorist financing or to the commission of related offences or an attempt thereof or with regard to which the obliged entity suspects or knows that it constitutes money laundering or terrorist financing or the commission of related offences.
    2. Victory Willbeours N.V. shall also notify the financial supervisory authorities in the event of a refusal to establish a business relationship as referred to in section 8 of these internal rules, as well as in the event of an extraordinary cancellation of a business relationship. Victory Willbeours N.V. will also notify the financial supervisory authorities if, following a due diligence request, the customer waives the establishment of a business relationship on its own initiative, as well as an attempt to enter into a transaction in which Victory Willbeours N.V. suspects money laundering or terrorist financing or the customer refuses to provide the required additional information.
    3. Victory Willbeours N.V. shall also notify the financial supervisory authorities in the cases specified in sections 12.3 and 12.6 of these internal rules, in connection with the determination of the situation of the financial sanction.
    4. As Victory Willbeours N.V. does not carry out cash transactions, Victory Willbeours N.V. does not have to notify the financial supervisory authorities of cash transactions.
    5. All notifications referred to in this section shall be made without delay, but no later than two working days after the suspicion.
  12. Identification of international financial sanctions and taking action

    1. When establishing a business relationship, Victory Willbeours N.V. checks whether the person wishing to establish a business relationship is subject to sanctions using a search engine on the financial supervisory authorities’ website. Victory Willbeours N.V. constantly monitors the website of the financial supervisory authorities and subscribes to the relevant newsletters in order to always know whether new persons have been added to the list of international financial sanctions and determines whether the person added to the list has a business relationship with Victory Willbeours N.V..
    2. Victory Willbeours N.V. shall, upon the entry into force, amendment or termination of a financial sanction, verify whether the person with whom it has a business relationship or who intends to do so is subject to the financial sanction.
    3. If Victory Willbeours N.V. identifies the subject of a financial sanction or that a transaction or action proposed or performed by it violates the financial sanction, it shall apply the financial sanction in accordance with the procedure specified in section 12.7 of these guidelines and immediately notify the financial supervisory authorities.
    4. If Victory Willbeours N.V. acknowledges that the risk is appropriate or has doubts as to whether a person with whom it does or intends to do business is subject to a financial penalty or a transaction or act proposed or performed by it violates a financial sanction, Victory Willbeours N.V. shall apply the financial sanction and the following due diligence measures:
      • a) collects additional information as to whether the person with whom it has a business relationship or is planning to do so is the subject of a financial sanction or the proposed or performed transaction or act violates the financial sanction and verifies it on the basis of additional documents, data or information from a reliable and independent source;
      • b) collects additional information about the purpose and nature of the business relationship, transaction or operation and verifies it on the basis of additional documents, data or information from a reliable and independent source.
    5. If a person in a business relationship, as well as a person intending to establish a business relationship, refuses to provide additional information or it is unable to determine whether the person is the subject of an international financial sanction, Victory Willbeours N.V. shall refuse to perform a transaction or act, take the measures provided for in the legislation establishing or enforcing an international financial sanction, and shall immediately notify the financial supervisory authorities of its suspicion and action.
    6. If Victory Willbeours N.V. identifies the subject of a financial sanction as a result of the application of due diligence measures, or if a transaction or action planned or performed by it violates the financial sanction, or if additional information obtained through the application of due diligence measures does not allow it to be identified, as well as in the event of a suspected breach of a financial sanction, Victory Willbeours N.V. shall inform the financial supervisory authorities thereof and of the financial sanction applied.
    7. Upon entry into force of an act establishing or implementing an international financial sanction, the contact person of the financial supervisory authorities shall take measures to comply with the obligations arising therefrom and shall exercise due diligence to ensure the achievement of the objective of the international financial sanction and to prevent violation of the sanction.
    8. Victory Willbeours N.V. shall, for a period of five years, collect and maintain the following information in fulfilment of its obligations under this section:
      • a) the time of the inspection;
      • b) the name of the person who inspected;
      • c) inspection results;
      • d) measures taken.
    9. Victory Willbeours N.V. is committed to comply with sanctions programs issued by (not only by Curaçao) the United Nations, Office of Foreign Asset Control (OFAC) of the United States, Her Majesty’s Treasury of the United Kingdom, European Union, and sanction programs placed by the local authority where any GIB entity operates. In that context, the Victory Willbeours N.V. is committed to prevent, detect and where applicable report any dealings with sanctioned persons.
  13. Suspicious activity

    1. Victory Willbeours N.V. reviews players spend and game play to check for suspicious activity. Before any withdrawal is processed the following procedures are carried out
    2. The customers deposit history is reviewed to confirm that no suspicious payments have been made to the customer’s account. The frequency of deposits and the sum of deposits are reviewed to ensure they are within normal range for the customer based on his depositing history and the general depositing range throughout our network.
    3. The customer’s turnover is reviewed to ensure that they have played in the casino and are not using Victory Willbeours N.V. as a method to move money.
    4. When possible, funds must always be refunded back to the original payment method used by the player to make a deposit.
  14. Withdrawal procedure

    1. When reviewing a customer’s account prior to withdrawal the agent must answer the following questions in the AML segment in the Risk Entry:
      1. Did the player wager?
      2. Does the payment Method belong to the player and has the player used it to deposit?
      3. Are the customer’s transactions and bets in line with expectations for the player?
      4. If one of the questions is answered no, then the Risk Entry must be put on Pending Management for review. The Risk Manager must review the case and submit an Internal SAR if the case is seen to be high risk. No withdrawal can be released to a customer whilst an investigation is ongoing.
      5. Transaction history is checked automatically for irregular patterns. A case is sent to the Risk Manager to red flag suspicious cases and an internal SAR is carried out where applicable.
      6. Transactions must be refunded to a payment method that has been used regularly and credit card deposits should be refunded to negate chargeback risk.
      7. DDC’s information must be filled in on the player’s records in the Customer Management System and all answers must be given.
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