Anti-Money Laundering (AML) Policy

1.1. The company’s management has extensive experience in protecting Jokabet gaming platforms from illegal activities. Anti-fraud and anti-money laundering measures have been implemented for many years and employees are trained.

1.2 Future training programs will be based on knowledge of the Proceeds of Crime Act and typical signs of money laundering, especially in the online environment.

1.3. The company director is well versed in the provisions of the Act and the duties to prevent money laundering. He has a successful track record in securing both online and land-based gaming projects.

2.1. Gaming platforms can be used for money laundering. Fast transactions and different payment methods make such platforms vulnerable.

2.2. Therefore, many internal decisions are made with these risks in mind – some are aimed directly at protection, others enhance security as part of the overall business strategy.

2.3. All employees are trained to recognize signs of suspicious activity, including:

• Unusual bets;
• Strange deposit and withdrawal schemes;
• Questionable customer data;
• Problems with identity confirmation;
• Communication between accounts.

2.4. If money laundering is suspected, the employee is obliged to inform the responsible person (MLRO), but not to notify the customer. Further action is only taken after approval. MLRO will send a report to Financial Intelligence Unit (FIU) through goAML system and maintain all necessary logs.

2.5. The company utilizes the Know Your Customer (KYC) policy. Customers are informed about possible checks and the need to provide documents at the time of registration or later.

2.6. Additional measures include:

• Limits on the amount and number of withdrawals;
• Verification and approval by the director of transfers from 3000 EUR at a time;
• Maximum of 3 withdrawals per day and no more than 9000 EUR per day.

2.7 Withdrawal of more than 3000 EUR in 24 hours or 9000 EUR in 90 days will require enhanced verification. Simple online verification is not suitable in such cases.

2.8. Cash is not used, which eliminates the risk of counterfeiting.

2.9. All account transactions are recorded and checked regularly. Suspicious bets and winnings will be further checked, including call history, to ensure there is no collusion between staff and customers.

2.10. A separate list of customers with high risk or political status is maintained – such accounts are checked more frequently and more carefully.

2.11. If employee misconduct is found, the company will investigate and take action in accordance with labor laws, including suspension.

3.1. Controls cover premises, equipment, employees, communications and operations. Different measures will be applied to ensure safety in all these areas.

3.2. A call recording system is utilized. This helps to:

• Train employees;
• Confirm the accuracy of rates and transactions;
• Protect customers and brand reputation;
• Identify possible collusion between customers and staff.

3.3. Protecting data, programs and equipment is a priority. All data that can be encrypted will be encrypted. Access to shared folders is restricted and password protection is utilized. Data is stored and backed up in a compliant manner so that outside access and loss does not occur.

4.1. The Terms of Use and KYC and AML rules will be posted on the website. It details the actions to take when fraud, foul play, suspected match-fixing and interactions with regulators are detected.

4.2. If serious crimes are suspected, the client will not be notified so as not to interfere with the investigation. Separate staff training is provided for such situations.

4.3. Relationships with other companies will also be checked. This includes standard background checks, signing confidentiality agreements, disclosure of founders and contact information. All information will be documented.