Anti Money Laundering Policy

Premier Sales Solutions N.V.

Company Registration Number: 145815
International Business Management Company B.V. Orionweg 5C Willemstad Curacao, CW 

 

 

Anti Money Laundering Policy

 

Introduction


Premier Sales Solutions N.V., is licensed and regulated by the Governor of Curaçao, to offer remote (on-line) games over the internet, under the Remote Gaming Regulations. Under the licence conditions issued by Curacao Authorities, Premier Sales Solutions N.V. is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity. 

Premier Sales Solutions N.V. is therefore obliged to follow the provisions contained in the legal framework namely the Prevention of Money Laundering Act (Chapter 373 of the laws of Malta), the Prevention of Money Laundering and Funding of Terrorism Regulations, (Legal Notice 188 of the laws of Malta) and any guidance notes issued by the relevant Authorities.

 

Objective of the Policy

 

Premier Sales Solutions N.V. is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimise and manage risks such as the risks to its reputational risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes. 

The company will endeavour to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organisation and its

operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.

 

Obligations

 

In order to adhere to the requirements of the Prevention of Money Laundering Act, the regulations and any guidance notes the company shall as a minimum:

- Appoint one of its senior officers as the designated Money Laundering Reporting Officer (MLRO) whose responsibilities will include the duties required by the laws regulations and guidance notes.

- Take reasonable steps to establish the identity of any person for whom it is proposed to provide its service. 
- For this purpose the process for the registration of Players provided for under the General Terms and Conditions provides for the due diligence process that must be carried out before the opening of a User Account.

- Keep at all times a secure online list of all registered Players.

- Retain identification and transactional documentation as defined in the laws regulations and guidance notes.

- Provide initial and ongoing training to all relevant staff so that they are aware of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions.

- Ensure that this policy is developed and maintained in line with evolving statutory and regulatory obligation and advice from the relevant authorities.

- Examine with special attention, and to the extent possible, the background and purpose of any complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism.

- Report any suspicion or knowledge of money laundering of terrorism financing to the Financial Intelligence Analysis Unit (FIAU) set up by law as the  Government Agency responsible for the collection, collation, processing, analysis and dissemination of information with a view to prevent money laundering and combat the funding of terrorism.

- Cooperate with all relevant administrative, enforcement and judicial authorities in their endeavour to prevent and detect criminal activity.


Moreover, the company shall:

- not accept to open anonymous Accounts or Accounts in fictitious names such that the true beneficial owner is not known.

- not accept cash from Players.

- Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other method approved by the Regulator.

- Not register a Player who is under eighteen (18) years of age.

- Only register a single account in the name of a particular person: multi-account practices are strictly prohibited.

- Transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.

- Not accept a wager unless a User Account has been established in the name of the Player and there are adequate funds in the Account to cover the amount of the wager.

not accept a wager unless the funds necessary to cover the amount of the wager are provided in an approved way.

- Not accept Players residing or playing from non-reputable jurisdictions.

- Not make a payment in excess of two thousand three hundred Euro (€ 2,300) or cumulative out of a User Account to a Player until the Player’s identity, age and place of residence have been verified.

- If no transaction has been recorded on a User Account for thirty months, close the User Account and remit the balance in that account to the Player, or if the Player cannot be satisfactorily located, to the regulator.

- Where it deems necessary, verify creditworthiness of the Player with third parties who previously provided any information on the Player.

- If it becomes aware that a person has provided false information when providing due diligence documents, not register such person. Where that person has already been registered, the company shall immediately cancel that person’s registration as a

Player with the company.

 

Politically exposed person

 

European guidelines regarding “The Prevention of Laundering the Proceeds from Criminal Activity (Money Laundering) and Terrorism Financing” entered into effect, changing the definition of politically exposed person. In order to minimize corruption and money laundering risks, Super Seven Investments Ltd is obliged by law to collect data and identify which of the clients / clients’ beneficiaries should be considered as politically exposed persons, their family members or close associates.

According to the law “On the Prevention of Laundering the Proceeds from Criminal Activity (Money Laundering) and Terrorism Financing” the following person shall be deemed a politically exposed person (hereinafter referred to as PEP): a person who holds or has held a prominent public position in a country of the European Union or European Economic Area or a third country, including senior-level state official, head of a state administrative unit (municipality), head of the government, minister (deputy minister or assistant deputy minister if there is such position in a relevant country), secretary of state or another high level official in the government or state administrative unit (municipality), member of parliament or similar legislative body, member of the management body (board) of a political party, judge of constitutional court, supreme court, or another level court (member of judicial body), member of the council or board of a supreme audit institution, member of the council or the board of a central bank, ambassador, charge d'affaires, armed forces higher officer, member of the council or board of a state capital company, head (director, deputy director) of international organization and member of the board or a person who holds an equal position at such organisation.

The following person shall be deemed a family member of a politically exposed person: a) a spouse or person considered to be the equivalent to a spouse. A person may be deemed the equivalent to a spouse only provided that he / she has such status under the laws of the respective country, b) a child or a child of a politically exposed person’s spouse or person considered to be the equivalent to a spouse, his / her spouse or person considered to be the equivalent to a spouse, c) a parent, grandparent or grandchild,

d) a brother or sister. A close associate of a politically exposed person is an individual publicly known to maintain business or other close relationship with a politically exposed person, or to be a shareholder in one and the same commercial company with a PEP, and also an individual who is the sole owner of such legal entity which is known to be actually established for the benefit of a PEP.

 

Forbidden Countries

 

The following countries are restricted from participation with Playbetpro: - Afghanistan, Albania, Algeria, Angola, Australia, Belgium, Cambodia, China, Democratic People’s Republic of Korea (DPRK), Ecuador, France, Guadeloupe, Guyana, Hong Kong, Indonesia, Israel, Iran, Iraq, Italy, Kuwait, Laos PDR, La Reunion, Malta, Martinique, Myanmar, Netherlands, Nicaragua, Norway, Pakistan, Panama. Papua New Guinea, Philippines, Saudi Arabia, Singapore, Spain, Sudan, Syria, Thailand, Uganda, UAE, USA, Yemen

 

Curacao, 03/01/2019

 

Premier Sales Solutions N.V.

Management