Anti-Money Laundering (AML) Policy
1. Overview
Raptor Entertainment N.V. (“LFG.bet” or the “Company”) was established in Curaçao in 2023 and operates the LFG.bet online gaming platform under license number OGL/2024/2363/1203, regulated by the Curaçao Gaming Control Board.
This Anti-Money Laundering Policy (“AML Policy”) outlines LFG.bet’s approach to preventing money laundering (“ML”) and terrorist financing (“TF”). It is aligned with Curaçao’s regulatory requirements and global best practices in the gaming industry, incorporating guidance from the Curaçao Gaming Control Board.
LFG.bet recognizes the risks of misuse by individuals or groups attempting to use its services for ML or TF and is committed to ensuring compliance, integrity, and transparency in all operations.
2. Purpose and Objectives
LFG.bet aims to ensure that its platform is not used for any illicit activities, such as money laundering (ML), terrorist financing (TF), or violations of international sanctions. To protect the integrity of the platform and meet legal requirements, LFG.bet follows global best practices in Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT), including:
- Implementing clear policies, procedures, and controls to help identify and reduce risks related to ML, TF, and sanctions violations.
- Appointing a Compliance Officer to oversee the AML measures and ensure the platform remains in line with regulations.
- Offering regular training and support to staff to maintain awareness of AML regulations and practices.
- Reviewing and updating AML procedures as needed to stay aligned with evolving laws, risks, and guidance from international bodies like the Financial Action Task Force (FATF) and the Curaçao Gaming Control Board.
The goal of this AML Policy is to set up an effective system for detecting and addressing any potential ML or TF activities within the LFG.bet platform, while ensuring compliance with all relevant laws and regulations.
3. Know Your Customer and Transaction Monitoring
LFG.bet employs a risk-based approach to customer verification and transaction monitoring to meet its AML obligations. This includes:
3.1 Know Your Customer (“KYC”)
LFG.bet’s Customer Due Diligence (“CDD”) process involves verifying the identities of all customers before they can engage in financial transactions on the platform. The process includes:
- Collecting Key Customer Information
LFG.bet may collect essential information such as full name, address, date of birth, country, postal code, and wallet addresses for identity verification when required.
- Restricted Jurisdiction Blocking
During the registration process, players are informed that LFG.bet does not operate in certain restricted jurisdictions. An IP-based geo-blocking system restricts access from these regions.
- Sanctioned Jurisdictions Controls
LFG.bet restricts access to players from countries or regions subject to international sanctions. Players must confirm they are not located in any prohibited jurisdiction during registration.
- Sanctions Screening: LFG.bet screens player wallet addresses against international sanctions lists using third-party blockchain compliance tools before issuing a funding address.
3.2 Continuous Monitoring
LFG.bet continuously monitors all players activities to detect potential ML, TF, or other suspicious behavior. Monitoring includes:
- Transaction Monitoring
Automated and manual processes are used to monitor transactions for suspicious behavior. If any suspicious activity is detected, withdrawals may be temporarily blocked, and the customer may be required to provide additional documentation for verification.
- Periodic Screening for Sanctioned Parties
Players' wallet addresses undergo regular re-screening against international sanctions databases to ensure compliance with sanctions laws.
- Detection of Unusual Behavior
LFG.bet monitors accounts for unusual transaction patterns, volumes, or behavior that may indicate illegal activities.
- Prohibition of Anonymity-Enhancing Services
Tools such as mixers or tumblers that obscure the source of funds are strictly prohibited. Customers using such services will face account restrictions.
- Blockchain Analysis
All crypto transactions are subject to blockchain analysis tools to identify suspicious patterns. High-risk accounts may be asked to provide proof of the source of their funds.
- Withdrawal Threshold Review
If a customer’s withdrawal exceeds predefined thresholds, additional due diligence may be performed to verify the legitimacy of the funds.
- Ban Evasion Prevention
LFG.bet uses advanced tools to detect customers attempting to evade platform bans or restrictions, such as using multiple accounts or transferring funds between accounts.
- Time Zone Checks
Customer location data is verified to ensure compliance with jurisdictional restrictions and to detect any evasion attempts.
- Service Provider Monitoring
Third-party service providers are regularly reviewed to ensure their compliance with AML regulations. LFG.bet may update or replace service providers as needed to maintain compliance.
3.3 Deposit Turnover Requirement Before Withdrawal
In compliance with our license requirements and for AML purposes, LFG.bet requires that all deposits made by a customer be turned over once before they are eligible for withdrawal. This is a precautionary measure designed to ensure that all funds being withdrawn are not directly tied to illicit activity or money laundering schemes.
3.4 Bonus Turnover Requirement Before Withdrawal
In addition to deposit turnover requirements, bonus funds are subject to specific turnover conditions before they can be withdrawn. The turnover requirement for bonuses varies based on the terms of the promotion and will be clearly outlined in the Bonus Terms and Conditions, as well as in the customers My Profile → Promos Page. Customers must meet these wagering requirements before requesting a withdrawal of any bonus funds.
Please note that bonus funds are not eligible for withdrawal until all bonus-specific turnover requirements have been met, and failure to fulfill these conditions may result in the forfeiture of the bonus.
3.5 Enhanced Due Diligence (EDD)
If suspicious activity is detected, LFG.bet will conduct Enhanced Due Diligence (EDD), which may include:
- Verifying the full legal name, citizen, residential address, and government-issued identification.
- Reviewing the customer’s source of funds and wealth, including documentation such as bank statements or business records.
- Investigating the customer’s financial activities and transactions in more detail.
Third-party services may be employed to assist in verifying the customer’s information.
3.6 Account closer and Suspension
LFG.bet reserves the right to close or suspend accounts if any of the following conditions are met:
- Failure to provide requested identification information.
- Submission of fraudulent or falsified documents.
- Attempting to conceal the true location of the customer.
- Accessing the platform from restricted or prohibited jurisdictions.
- Being listed on sanctions databases or engaging in suspicious activities.
- Exhibiting signs of gambling addiction or other problematic behavior.
- Depositing funds originating from prohibited jurisdictions.
In addition, LFG.bet may suspend accounts based on other compliance-related concerns at its discretion.
4. Education and Training
LFG.bet is committed to ensuring compliance with AML regulations. To achieve this, the company regularly provides its employees with the necessary training to ensure they understand and comply with the policies, procedures, and controls in place to prevent money laundering (ML), terrorist financing (TF), and sanctions violations.
Training sessions are conducted periodically, focusing on the identification of suspicious activities and the company’s responsibilities under AML laws. The company's efforts are supported by guidance from legal experts and are overseen by the designated Compliance Officer to ensure that the training remains relevant and effective in line with regulatory updates and emerging risks.
5. Reporting Obligations
In cases where a player appears on a sanctions list or when activities suggest potential ML, TF, or other criminal behavior, LFG.bet may be required to file a report with the relevant authorities, including Curaçao’s Financial Intelligence Unit (FIU), as required by law.