AML Policy

Please read this policy carefully to understand how the company tries to prevent money laundering on its website and how the company aims to combat illicit and illegal activities. The company provides you insight into the verifications, checks, and compliances done on the website for all services. If you disagree with our policies, terms, and practices, you may not access our website or use any service offered on it, disregarding if the company or its third-party partners provide them. All gambling services and chat services on the website are conditioned on your acceptance of these terms. By accessing our website, you agree to only use our services under the conditions mentioned in our terms. Please regularly check our terms for updates and changes.

Definitions:

Website: refers to Privatebet.com and www.privatebet.com
Company: refers to XYZ Entertainment
WE or US or OUR: refers to the company
Country: Refers to Curacao
Governing law: refers to the laws of Curacao
Terms: refers to this Agreement (Terms of Service) in addition to the Privacy Policy,
KYC-AML-Policy, and Responsible Gambling Policy
Account refers to a player's user account created on Privatebet.com under this agreement.
User: refers to any natural individual using services on Privatebet.com under the terms.
Player: refers to any user of our services
Affiliate: refers to any other user who joins via your invite link/code,
AML: refers to Anti-money laundering, further information in our KYC-AML policy
AMLCO: stands for Anti Money Laundering Compliance Office
KYC: refers to Know your Customer, further information in our KYC-AML policy
Support: refers to the Privatebet Support team and the Privatebet Compliance team
Game: refers to any gambling services on the website, including games of skill, games of chance, and games of risk
Third-party partner: refers to all of the companies business associates.

For Cash Deposits and Cash Withdraws

(AML Anti-Money-Laundering policy of www.Privatebet.com, by XYZ Entertainment BV) The objective of the AML Policy: The company and its third-party partners seek to offer the highest security to all of our users and customers onwww.Privatebet.com; for that, three-step account verification is done to ensure the identity of our customers. The first step is general KYC, second and third steps are advanced Anti Money Laundering checks. In doubt, we may add a fourth step for clarification. This is to prove that the details of the person registered are correct and the deposited values are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also consider that depending on the nationality and origin, the way of payment, and for withdrawing extra safety, measurements must be taken.

The company also puts reasonable measures in place to control, limit, and avoid ML risk, including dedicating the appropriate means for www.Privatebet.com.

According to the EU guidelines, the company and its third-party partners are committed to high standards of anti-money laundering (AML) and compliance and require management and employees to enforce these standards to prevent the use of its services for money laundering purposes. XYZ Entertainment BV also takes additional safety measures to handle the higher risk of payments made with cryptocurrencies.

The AML program of www.Privatebet.com is designed to be compliant with :

EU: "Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering."
EU: "Directive 2018/843 the fifth anti-money laundering directive which amended the 4th anti-money laundering directive (Directive 2015/849) to further improve the anti-money laundering program of the European Union and its partners.
EU: "Regulation 2015/847 on information accompanying transfers of funds."
EU: Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
BE: "Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash
EU: first and second Risk assessment published by the European Commission 26 June 2017 and 24 July 2019. The commission assessed the vulnerability of financial products and services to risks of money laundering and terrorist financing. This risk analysis is conceived as a key tool to identify, analyze, and address money laundering and terrorist financing risks in the EU.
EU: planned directive 6AMLD for 2021 to combat money laundering via cryptocurrencies and cyber criminality.

Definition of Money Laundering

Money Laundering is understood as:

The conversion or transfer of property, especially money, but not exclusively money, knowing that such property is derived from criminal activity or from taking part in such activity, to conceal or disguise the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person or companies action;
The concealment or disguise of the true nature, source, location, disposition, movement, rights concerning, or ownership of, property, knowing that such property is derived from criminal activity or an act of participation in such activity;
The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such activity;
Participation in, association to commit, attempts to commit and aid, abet, facilitate, and counsel the commission of any of the actions referred to in points before;
Besides, untaxed income, such as black money, shall not be accepted and reported to the corresponding government agency to ensure fair taxation and legal prosecution.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

Organization of the AML for the website

Following the AML legislation, the company has appointed on its and its third-party partner's behalf the "highest level" for the prevention of money laundering: The full management of the company is in charge and responsible.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of enforcing the AML policy and procedures within the system. The AMLCO is also in charge of constantly adjusting the AML to deal with all upcoming difficulties when preventing Money Laundering.

The AMLCO is placed under the direct responsibility of the general Management and part of the comprehensive Management.

AML and KYC policy changes and implementation requirements

Each major change of AML policy and KYC policy is subject to be approved by the company's general management and the AMLCO. The company reserves the right to adjust, modify, or replace these terms and guidelines at any time, at our sole discretion. The company may have to adjust, modify or replace the terms and guidelines to comply with further changes in laws and regulations, as well as further threats of money laundering and illicit or illegal activities

The company will annually adjust the AML and KYC risk assessment and adjust its terms according to it. The company aims to prevent money laundering and illegal or illicit activities on the website and all services connected to it.

Three-step Verification

Step one

Step one verification is a simple KYC (Know your customer), which must be done by every user and customer to withdraw as recommended in Directive 2018/843. Disregarding the payment choice, the amount of payment, the amount of withdrawing, the choice of withdrawing, and nationality of the user or customer, step one verification must be done before any withdrawal or transaction to another user can be made.

Step one verification is an online document that must be filled out by the user/customer himself faithfully. The following information must be filled in: first name, second name, date of birth, country of usual residence.

We do not allow any withdrawal of funds until the KYC is filled in and approved. In case of misinformation or unfaithful filling in, the company may hold the funds until the KYC is approved. We might ask you to do Step two verification before withdrawing any funds if you filled in intentionally wrong information in the KYC online document.

Step two

Step two verification, an ID check, and electronic origin check must be done by every user which deposit over a certain threshold as mentioned in Directive (EU) 2015/2366 or withdraws a certain threshold as mentioned in Directive (EU) 2015/2366 or sends another user over 50% (fifty percent) of the threshold as mentioned in Directive (EU) 2015/2366 over 24 months.

Until step two verification is done, the withdrawal, tip or deposit will be held. Step to verification will lead the user or customer to a subpage where he must submit his ID. The user/customer has to take a picture of his ID. Only an official ID may be used for ID verification; depending on the country, the variety of accepted IDs may differ. (Normally, these are: Driving license, Passport, Identity card. Depending on your country of origin, this may variate).

There will also be an electronic check if the filled-in personal data from step one verification, the KYC, match. The electronic check will check via two different data banks to ensure the given information matches the filled document and the ID's name. Also, this electronic check cross-checks the origin of the user or customer and his state of residence and address.

If the electronic test fails or is not possible, the user/customer must send in a confirmation of his current residence. A certificate of registration by the government or a similar document isrequired. In cases where no such certificate exists, the utility bills of the last 3 (three) months may be used.

Step three

Step three verification, verification of the source of funds, must be done by every user which deposit over the second threshold mentioned in Directive (EU) 2015/2366 or withdraws over the second threshold mentioned in Directive (EU) 2015/2366 or sends another user over 60% (sixty percent) off the second threshold as mentioned in Directive (EU) 2015/2366), over 24 months.

Until step three verification is done, the withdrawal, user tip, or deposit will be held. For step 3, a user/customer will be asked for a source of wealth. The user or customer has to upload a document proving his source of wealth via a subpage.

Source of funds / wealth

If a player deposits over five thousand euro, there is a process of understanding the source of funds / wealth.

Examples of SOW are:

Ownership of business
Employment
Inheritance
Investment
Family

The origin and legitimacy of that wealth must be clearly understood. If this is not possible, an employee may ask for an additional document or prove.

Customer Identification and Verification

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy.

This identification relies on the following fundamental principles:

A copy of your passport, ID card, or driving license, each shown alongside a handwritten note mentioning a six digits randomly generated number. Alternatively, the copy of your passport, ID card, or driving license, each shown alongside your face clearly visible.

Please note that all four corners of the ID have to be visible in the same image, and all details have to be readable besides the named above.

An employee may do additional checks if necessary, based on the situation.

Proof of Address

Proof of address may be done via different electronic checks, which use different databases.

If an electronic test fails, the user or customer can make a manual proof of address. A recent utility bill was sent to your registered address, issued within the last 3 (three) months, or an official document made by the government that proves your state of residence.

An employee may do additional checks if necessary, based on the situation.

Basic online document for KYC

The basic document will be accessible via the setting page on www.Privatebet.com. Every user has to fill out the following information's:

Examples of SOW are:

First name
Second name
Nationality
Date of birth

The document will be saved and created by an AI; an employee may do additional checks if necessary based on the situation.

Social media cross-check

Our Privatebet Compliance team may ask you to connect your Facebook account with your Privatebet user account to support our KYC verifications and checks.

If you choose to connect your Facebook account with your Privatebet user account, the company gets access to all your information, posts, pictures, and location data connected to your Facebook account.

If you do not wish to connect your Facebook account with your Privatebet user account, you are free to do so and instead complete the AML 1 Verification to verify your Privatebet user account.

The system will use your Facebook account to cross-check all information given by you in the KYC check for accuracy and completeness. The company and third-party partners will not post anything from your account or affect your Facebook account in any visible way.

Sanctions, Persons and Entities of Special Interest as well as PEPS

The www.opensanctions.org database is used for screenings of open sanctions. The website is a global database of persons and companies of political, criminal, or economic interest. It combines the most important sanctions lists, databases of politically exposed persons, and other public information into a single, easy-to-access dataset. It Cross-checks leeks and public databases for possible conflicts of interest and signs of illicit or illegal activity, tracks political conflicts, compares worldwide sanctions policies, and checks potential customers, users, and partners in international dealings. The project includes sanctions lists, lists of politicians, ban lists used in government procurement, lists of known terrorists, and other data sources relevant to journalistic research and due diligence.

In order to facilitate the use of this database, the company has created a script that incorporates the OpenSanctions search engine on the website. The user will sign up and add their name and e-mail address into our script. Before they move onto the next stage of checks, a script extracts their name and scans this through the database to ensure that they are not a listed person. If the results come back negative, the customer will not be able to enter the site, and we will inform authorities.

The company and its trusted third-party partners will also have a subscription to namescan.io Furthermore, the company will be supported by UNISERV in their checks for possible fraud, companies of political, criminal interests. Their advanced system fully cooperates in its intern system, and the intern system is used together with its third-party partners.

Reporting of Suspicious transactions on the website

In its internal procedures, the company describes in precise terms, for its staff members' attention, when it is necessary to report and how to proceed with such reporting. Reports of atypical transactions are analyzed within the AML Compliance team following the precise methodology described in the internal procedures.

Depending on the result of this examination and based on the information gathered, the AML team :

will decide whether it is necessary or not to send a report to the FIU, following the legal obligations provided in the Law of 18 September 2017;
will decide whether or not it is necessary to terminate the business relations with the customer.

Record keeping

Records of data obtained for identification must be kept a minimum of ten years after the business relationship has ended, as required by law

Records of all transaction data must be kept for at least ten years following the transactions' carrying-out or the end of the business relationship.

Data Security

All data given by any user or customer will be kept secure, will not be sold or given to anyone else. Only if forced by law or the exceptions mentioned in the companies Privacy Policy to prevent money laundering data may be shared with the AML-authority of the affected state.

Further information you can find in the companies Privacy Policy.

The company and www.privatebet.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC).

Case Reporting and Punishment

When dealing with a case of money laundering or any suspicion of money laundering or fraud, illicit or illegal activity, the company may freeze any user account until the suspicion is cleared. The AMLCO may ask any user for additional information before clearing the suspicion. The AMLCO will forward any case of money laundering to the authorities. The company and its third-party partners are not responsible for any legal consequences a user may face for illegal or illicit activities.

The company has the right to ban any user immediately and suspend any account from its websites Privatebet.com and www.Privatebet.com and all services offered on it, when detecting money laundering, or a user fails to comply with the companies AML-KYC Policy or fails to comply with the AML Compliance team or AMLCO, or any other illegal or illicit activity is found. The company and its partner aim to fully cooperate with the authorities in the shared fight against illicit and illegal activities and money laundering.

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