AML Policy by Joymatik N.V.
Last update: 07/12/2022
For cash withdrawals and cash deposits
AML – Anti-Money-Laundering policy of betshah.net .
Introduction: Betshah.net was operated by Joymatik N.V. with its address at Address: Abraham de Veerstraat 9, Willemstad. Company registration number 157399
AML Policy Objective: To offer maximum security to all our customers and users on Betshah.net, we have implemented a three-step account verification to ensure that our customers are authentic. This is done to verify that the registered details are accurate and that the deposit methods are not being stolen or used by another person. It also creates the framework for fighting money laundering. Also, we consider that the method of payment and withdrawal must be determined based on nationality and origin.
betshah.net has reasonable measures in place to limit and control ML risk. This includes dedicating the necessary means.
betshah.net adheres to strict anti-money laundering standards (AML) as set forth by the EU guidelines. Management and employees are required to enforce these standards to prevent money laundering.
Betshah.net‘s AML program is compliant with:
EU – “Directive 2015/849 (of the European Parliament and The Council of 20 Mai 2015) on the prevention of financial systems being used for money laundering”
EU: “Regulation 2015/847 concerning information associated with transfers of funds”
EU : There are a variety of regulations that impose sanctions on persons or restrict their movements and embargos on certain goods and technologies, as well as those that prohibit dual-use goods.
BE : “Law 18 September 2017 on money laundering prevention and limitation of the cash use
Definition: Money laundering
Money laundering is defined as:
- Conversion or transfer of property, particularly money, knowing that it is derived from criminal activities or taking part in such activity. This is done in order to conceal or disguising the illegal source of the property or to help any person involved in such an activity to avoid the legal consequences.
- It is the concealment or deceit of the true nature, location, disposition and movement of property. This could be done knowing that it is derived from criminal activities or an act of participation in such activity.
- It is the act of acquiring, possessing, or using property knowing that it was obtained from criminal activity or assisting in such activity.
- Participation, association to commit, attempts at commit and aiding in the commission of any of these actions.
Money laundering will be considered money regardless of whether the activities that led to the property being laundered were conducted on the territory of another member state or a third party.
Organization of the AML For Betshah.net:
Betshah.net, in accordance with AML legislation has designated the “highest” level for the prevention and detection of ML: Joymatik N.V.’s entire management.
AMLCO (Anti Money Laundering Compliance Officer), is responsible for the enforcement of AML policies and procedures within the system.
The AMLCO falls under the direct supervision of the General Management.
AML Policy Changes and Implementation Requirements:
Every major change to the Betshah.net AML Policy must be approved by Joymatik N.V.’s general management and the Anti Money Laundering Compliance Officer.
Three step Verification:
Verification step one:
Every customer and user must complete step one verification before they can withdraw. To withdraw, each user/customer must first verify their identity and choose the payment amount. The customer/user must complete step one verification. The following information must be entered: date of birth, first and last names, full address, gender, country of usual residence, gender, and last name.
Every user who deposits or withdraws more than 2000$ (two million Dollars) must complete step two verification. The withdrawal, tip, or deposit will not be processed until step two verification has been completed. The customer or user will be directed to step two verification, where he will need to submit his ID. The customer/user must take a photo of their ID. A paperclip with a six digit random generated number is placed next to the ID. Only an official ID can be used for ID verification. The country may have different IDs. If the data from step one verification has been correctly filled out, there will be an electronic check. Two data banks will be used to verify that the information is correct. If it fails, the customer/user must send in proof of current residence. You will need a certificate of registration from the government or another similar document.
Every user who deposits more than 5000$ or withdraws more than 5000$ or sends someone over 3000$ (3000 Dollars) must complete step 3. Step 3 will require the customer/user to provide a source for wealth.
Customer identification (KYC),
It is essential that customers are properly identified when entering into commercial relationships. This is true for both the KYC policy and the regulations regarding money laundering.
These are the fundamental principles that underpin this identification:
You will need a copy of your passport, driving licence, or ID card. Each must be shown with a handwritten note that includes six randomly generated numbers. A second photograph of the customer/user is also required. Each information may be blurred by the customer/user, including date of birth, gender, first and second names, as well as the picture. To protect their privacy.
It is important to note that the ID must be visible from all four corners. All details, including the name, must also be clearly legible. If necessary, we may ask for any additional details.
Based on the circumstances, an employee might perform additional checks.
Proof Of Address:
Two different databases are used to verify the address. The customer/user can request a paper proof if the electronic test fails.
Recent utility bills sent to your registered address within the last three months. Or an official document issued by the government which proves your residence.
Please ensure that the document you send has a clear resolution so that all corners are visible and that all text is easily readable. This will speed up the approval process.
Example: A bill for electricity, water, or bank statements.
Based on the circumstances, an employee might perform additional checks.
Source for funds
A player who deposits more than five thousand euros can be helped to understand the source of their wealth (SOW).
These are examples of SOW:
- Business ownership
It is crucial that you understand the source and legitimacy of this wealth. An employee might request additional documentation or proof if this is not possible.
If the account is frozen, it will be frozen by any user who deposits this amount in more than one transaction. To go over the information and to send them an email, they will need to manually enter the information.
betshah.net asks for a bank wire/creditcard to further protect the identity of the customer/user. The financial information of the customer/user is also included.
You can access the set page at .net to view the basic document. Each user must fill in the following information:
- First name
- Second name
- Date of birth
An AI will save the document and create it. Employees may perform additional checks depending on the circumstances.
To deal with the various risks and states of wealth in different areas of earth Betshah.net will classify every nation into three distinct regions of risk.
Region one: Low risk
Each country from a region has to be verified in the same three steps as previously described.
Region two: Moderate risk
Each country from the region two will undergo three-step verification at lower deposits, withdrawals and tips amounts. Step one will continue as normal. Step two will take place after you have deposited 1000$ (one million dollars), withdrawn 1000$ (one hundred thousand dollars) or tipped another customer/user 500$ (five hundred dollars). Step three will take place after you have made a deposit of 2500$ (two thousand five hundreds Dollars), withdrawn 2500$ (2 thousand five hundred dollars) or tipped another customer/user 1000$ (1 thousand). Users from low-risk regions that convert crypto currency into any other currency will also be treated as customers/users from a medium-risk region.
High risk in Region Three
High-risk areas will be exempted from the ban. High-risk regions will be updated regularly to keep up with changing world.
AML compliance officer will also oversee an AI that looks for unusual behavior and immediately report it to betshah.net.
Based on a risk-based few and general experience, the AI and other employees may recheck any checks that were done previously by human employees. They may also redo or perform additional checks depending on the situation.
A data scientist supported by electronic analytic systems can also look out for unusual behaviours such as: Depositing or withdrawing without longer betting sessions. If the account’s owner is still using it, it will be possible to deposit and withdraw from a different Bank account.
To prevent money laundering, a User must use the same withdrawal method as for deposit to withdraw the initial deposit amount.
Enterprise-wide risk assessment
Betshah.net conducted an AML (Enterprise-wide Risk Assessment) in order to understand and identify risks that are specific to Betshah.net as well as its business lines. After identifying and documenting all risks associated with its business lines, such as the services it offers, the AML risk policy is established. These include the Users who are eligible for services, the transactions they perform, the delivery channels used and the geographical locations of bank operations, customers, and transactions, as well as other emerging and qualitative risks.
The Betshah.net comprehension of regulatory requirements, industry expectations and industry guidance is used to identify AML risk categories. To protect against the extra risks that the internet brings, additional safety precautions are taken.
Every year, the EWRA is reassessed.
Continuous transaction monitoring
AML-Compliance is a system that monitors transactions to identify suspicious or unusual transactions.
Two levels of transaction monitoring are used:
1) The first line of control:
betshah.net only works with trusted Payment Service Providers that have effective AML policies to stop suspicious deposits onto Betshah.net without proper execution KYC procedures.
2) The second line of control:
betshah.net informs its network so that any contact made with a customer, player or authorized representative will result in due diligence regarding transactions on the account. These include:
- Requests to execute financial transactions on the account
- Requests for payment methods or services;
The three-step verification and adjusted risk management should also provide all information regarding all customers of Betshah.net at any time.
All transactions must also be monitored by employees who are supervised by an AML compliance officer, who is supervised by the general manager.
Due diligence must be exercised on all transactions that are submitted to customer support managers, or through their Compliance Manager.
The subjective assessment of the customer (KYC), financial behavior and transaction counterparty is the basis for determining the unusual nature of any or all transactions.
The checks will be performed by an automated system, and an employee will cross-check them to ensure additional security.
Transactions observed on customer accounts that make it difficult to understand the lawful activities or origin of funds should be quickly deemed atypical, as they are not directly justified.
Betshah.net employees must notify the AML division any unusual transactions they observe, but cannot attribute to a legal activity or source income known to the customer.
3) The third Line of Control
Betshah.net will perform manual checks on any suspicious or high-risk users to prevent money laundering.
Authorities will be notified if fraud is detected or money laundering is suspected.
Reporting suspicious transactions on Betshah.net
Betshah.net outlines in detail, for the attention its staff, when it is important to report and how to do so.
AML team members analyse reports of unusual transactions in accordance to the exact methodology detailed in the internal procedures.
Based on the results of this examination, and the information gathered by the AML team:
- In accordance with the Law of 18/09/2017, the FIU will decide whether or not it is necessary to send a report.
- The customer will decide if it is necessary for them to end their business relationship.
The AML rules, which include minimum KYC standards, will be converted into operational guidance or procedures on the Intranet site .
Keep records of any data used for identification for at least ten year after the end of the business relationship.
All transaction data must be retained for at least ten year after the conclusion of any business relationship or transactions.
These data will be encrypted and stored offline as well as online.
The betshah.net employees will perform manual controls on approvals based on risk. They also receive special training.
Its use reflects the training and awareness program.
- A mandatory AML Training Program in compliance with the most recent regulatory developments, for all those in touch with finance
- All new employees are invited to attend AML academic learning sessions
This training program must be tailored to the type of business that the trainees work for and the positions they hold. These sessions are delivered by an AML-specialist who works in the Joymatik N.V. AML department.
Regular internal audit establishes missions to report on AML activities.
Any data provided by customers or users will be kept confidential and will not be given or sold to any other person. Only data that is required by law or necessary to prevent money laundering may be shared with AML-authorities of the affected state.
betshah.net follows all rules and guidelines of the data protection directive (officially Directive 1995/46/EC).
Contact us if you have any questions regarding our AML or KYC Policy
By email: [email protected]
Please contact us if you have any complaints about our AML/ KYC Policy, or about the checks made on your Account and Person.
By email: [email protected]