This document outlines the Anti-Money Laundering (AML) policy for SweepstakeBingo.com, an online bingo platform offering an entertainment platform for online games. The purpose of this policy is to establish controls and procedures to prevent, detect, and report money laundering activities in compliance with applicable laws and regulations.
2. Scope
2.1 Scope:
This policy applies to all employees, contractors, and third-party service providers of SweepstakeBingo.com. It covers all transactions, customer activities, and business relationships conducted on or through the platform.
3. Key Objectives
3.1 Prevent Money Laundering:
Implement measures to prevent the use of SweepstakeBingo.com as a means of laundering illegal funds.
3.2 Detect Suspicious Activities:
Identify and monitor transactions that may indicate money laundering or other financial crimes.
3.3 Report Suspicious Activities:
Submit reports of suspicious activities to the relevant financial intelligence unit (FIU) in accordance with legal requirements.
3.4 Comply with Regulations:
Ensure compliance with all applicable AML laws, regulations, and industry standards.
4. Risk Assessment
4.1 Customer Risk Assessment:
Perform risk assessments on all customers based on their profile, including high-risk customers such as those from high-risk jurisdictions, politically exposed persons (PEPs), or individuals with a history of suspicious activity.
4.2 Geographic Risk Assessment:
Monitor transactions involving countries or regions designated as high-risk for money laundering.
4.3 Transaction Risk Assessment:
Review and monitor transactions flagged as suspicious based on predefined criteria, such as transactions exceeding a specific threshold ($200), unusual patterns of activity, or anonymous accounts.
5. Customer Due Diligence (CDD)
5.1 Enhanced Due Diligence (EDD):
Apply enhanced scrutiny to high-risk customers, including verifying identity, assessing source of funds, and monitoring activity for unusual behavior.
5.2 Standard Due Diligence (SDD):
Verify identity and maintain records of verification. Conduct periodic reviews of customer accounts to ensure information is up-to-date.
5.3 Simplified Due Diligence (SDD):
Apply reduced scrutiny to low-risk customers, such as those with low-value transactions.
6. Transaction Monitoring
6.1 Automated Monitoring:
Use transaction monitoring systems to identify and flag suspicious activities in real-time.
6.2 Manual Review:
Conduct manual reviews of flagged transactions to determine if they require further investigation or reporting.
7. Reporting Requirements
7.1 Suspicious Activity Reports (SARs):
File SARs with the relevant FIU for any transactions that appear suspicious or involve funds linked to illegal activities.
7.2 Threshold Reporting:
Report cash transactions exceeding $1000 to the FIU, as required by law.
7.3 Regulatory Reporting:
Ensure compliance with all reporting requirements, including deadlines and format specifications.
8. Training and Awareness
8.1 Employee Training:
Provide regular training on AML policies and procedures, and ensure employees understand how to identify and report suspicious activities.
8.2 Awareness Campaigns:
Conduct regular AML awareness campaigns to educate employees on the risks of money laundering and the importance of compliance.
9. Record-Keeping
9.1 Retention of Records:
Maintain records of transactions, customer identities, and suspicious activity reports for a minimum of five years, as required by law.
9.2 Audit Trails:
Ensure all activities and transactions are logged with audit trails for review by auditors and regulators.
10. Audit and Compliance
10.1 Internal Audits:
Conduct regular internal audits to review the effectiveness of AML controls and procedures.
10.2 External Reviews:
Engage third-party auditors or AML experts to review the AML framework periodically.
10.3 Regulatory Inspections:
Cooperate fully with regulatory authorities during inspections or investigations.
11. Enforcement and Penalties
11.1 Non-Compliance:
Non-compliance with this policy may result in disciplinary action, including termination of employment or business relationships.
11.2 Regulatory Penalties:
Failure to comply with AML regulations may result in fines, legal action, or other penalties imposed by regulatory authorities.
12. Continuous Improvement
12.1 Review and Update:
Review and update this policy regularly to ensure compliance with changes in laws, regulations, or industry standards.
12.2 Feedback and Suggestions:
Encourage employees to provide feedback and suggestions for improving the AML framework.
13. Approval and Authorization
13.1 Approval:
This policy has been approved by SweepstakeBingo.com management and is authorized for implementation.
