Version 1.3
In order to do a first deposit with SkyOwa B.V. a customer needs to provide the following mandatory details:
2. A newly registered SkyOwa B.V. account has to be checked immediately by the service department in order to find out if the details are correct (accounts with false names and addresses will be closed). Also the registered country and the IPсountry need to be compared. A mismatch is automatically to be noted in the customers’ account. This helps us close fake accounts before any payin can be processed.
On each payout it has to be checked if the deposits have been used for stakes. A payout cannot be processed if the deposited amount has not been used for stakes. If the deposited amount has not been used, the payout has to be denied. Furthermore, the latest winnings have to be checked for correctness.
Before a payout can be deducted from the customer´s account, the account has to be checked if a bonus has been given to the customer since the last payout. When a bonus has been credited, the account has to be checked for fulfillment of the bonus rules applicable to that bonus.
The risk-based approach is introduced to promote a move away from a “one size fits all” approach to anti-money laundering procedures. By identifying and assessing the money laundering risks, SkyOwa B.V. can take the best steps to mitigate and monitor those risks.
Based on our business profile, the risk of money laundering and terrorist financing is minimal, especially compared to financial institutions. The main reason is that cash is not accepted and only credit cards, ewallets and other licensed instruments can be used to effect deposits and withdrawals. Additionally, the average transaction is of a relatively small value. The only money laundering stage that could be of a risk potential for SkyOwa B.V. , is the layering stage, which is mitigated by various daily screening measures described below.
CDD information is needed to identify money laundering activity. The more the customer profile is updated, the more it will help to identify unusual and potentially suspicious activity. In accordance with the 4th AML directive, the verification and gathering of client information will be delayed until: Account deposits reach a pre-determined threshold of EUR 2,000 Gaming activity reaches a pre-determined threshold of EUR 2,000 Players seek to withdraw funds (initial payout) A period of time since account opening lapses more than 60 days.
The following on-going monitoring measures describe CDD measures based on the company’s risk profile: Identity verification for every new customer Assessing the risk profile of every customer Daily payout analysis Analysis of the historical pattern of the customer’s payout activity Ban of anonymous or fictitious accounts.
The daily CDD measures applied during the daily workflow are described in detail below.
For every new customer the service department conducts individual checks whether the registered data is plausible and correct. The IP address check and double customer check are conducted as outlined below. Fake or double accounts are being closed immediately.
The customer’s IP address is registered upon every log-in. Upon registration, a review is done as to whether the customer’s IP address corresponds with the registered country. If there is a mismatch, the customer’s account is marked for further checks.
Every customer can open only one SkyOwa B.V. account. If a customer tries to open multiple accounts, these will be blocked, and the system will generate a warning.
Customers may need to submit a passport copy before the first pay-out irrespective of the amount requested. Passport copies are checked individually by risk management. Furthermore, SkyOwa B.V. reserves the right to determine the payment means of the first pay-out: either by the same method used for the deposit, or by bank transfer in order to further validate the customer’s identity.
After the identity verification a risk profile is formed based on the behavioral pattern of the customer. Every customer is given an internal classification, which will be described further below. If suspicious behavior is observed, evidence will be recorded on the customer profile, and enhanced customer due diligence is applied. Enhanced customer due diligence (EDD) is mandatory also for Politically Exposed Persons (PEPs) who are considered highrisk customers.
Enhanced Customer Due Diligence is applied when additional steps of examination are needed to identify the customer and to confirm that their activities and funds are legitimate. The following measures describe EDD measures based on the company’s risk profile: ● Establishing the identity of the customer by requesting additional documents such as: a copy of a utility bill to verify the home address and a statement of a credit or financial institution to prove the bank account holder.
The daily EDD measures applied during the daily workflow are described in detail below.
The customer has to submit ID, utility bill and bank statement for Enhanced ID Check within 30 days. If the customer does not send these documents within 30 days, the gaming account will be blocked from all transactions. Enhanced IDCheck is carried out whenever: ● The registered country is not part of the FATF white list.
● A deposit or pay out request is equal or more than 2,000 EUR.
We use common tools like 3D Secure to verify credit cards.
The MLRO is the first person to notify when the suspicion of money laundering activities evolves. The MLRO is appointed by senior management and is trained for the money laundering risk factors that the company faces. When the company appoints the MLRO, the competent authorities need to be notified. The main duties of the MLRO are: a) Keeping up to date with AML/CTF legislations.
b) Making sure that implementation takes place in line with the internal procedures.
c) Making sure that anti-money laundering training is periodically given to staff.
d) Recording and updating risk assessments.
e) To receive and evaluate internal reports.
f) To advise, guide and assist.
g) To keep statistical data.
h) Filing STRs to the respective financial authority.
All incidents involving a suspicious person or transaction in terms of money laundering or funding terrorism need to be reported to the respective financial authority by the MLRO within 5 working days. In the Suspicious Transaction Report, the MLRO must give a clear and complete explanation of the suspicious behavior including also customer identification and transaction records.
Every customer is vetted in a specific customer class according to his „risk potential “. Every customer class is subject to different deposit limits. For instance, all new customers are being rated with customer class N (white list markets) or M (non-white list countries). After the lapse of 4 weeks, customers will be moved to different classes in line with their observed behavior. High risk customers will be followed closely.
A Politically Exposed Person is someone who has been entrusted with a prominent public function, such as a senior political figure. Individuals who are closely related to this person, for instance, immediate family members and close associates, are also considered as PEPs. PEPs are classified as a money laundering risk since they may be exposed to property that has been generated by corruption and bribery because of their position. The current PEP lists provided by Acuris are consulted in order to identify a customer as PEP. The player is requested to confirm their PEP status within the first deposit. Once established as PEP, the user’s account is terminated at SkyOwa B.V. Screening for PEP status is carried out once a year and after a country election the resident of which the player is. Where player who was a PEP is no longer entrusted with a prominent public function, the requirements for PEPs will continue to apply for a period of at least 12 months after the date on which the person ceased to be entrusted with a public function or for a longer period to address the risks of money laundering or terrorist financing in relation to that person.
Periodical training ensures that the staff is aware and compliant with the anti-money laundering regulatory requirements.
For all new employees hired by SkyOwa B.V. ; SkyOwa B.V. will conduct a thorough background check and various due diligence documents will be collected for reference (birth certificate, clear police conduct, etc.). Interviews are carried out and requested references are checked, whenever available. It is a company policy that all new employees are also given training with regards to the anti-money laundering policy and the internal procedures used to mitigate this risk.