Aml

Introduction

80 Win operates as a remote gaming entity under Curaçao law. This Anti-Money Laundering (AML) Policy establishes the framework to prevent money laundering and the financing of terrorism in relation to all activities conducted on the 80 Win platform. The Policy implements applicable national and international requirements, including supervisory guidance and recognized standards governing the prevention of financial crime in online gaming.

Regulatory Framework and Supervisory Authority

80 Win recognises the Financial Intelligence Analysis Unit as the competent supervisory authority responsible for overseeing AML/CFT compliance. The Policy aligns with the Curaçao framework, including the relevant ordinances governing games of chance, as well as international guidance adopted by Curaçao in line with FATF recommendations. The operator undertakes ongoing compliance with these requirements, including customer due diligence, record-keeping, and reporting obligations.

Scope and Application

This Policy applies to all customers, accounts, and transactions conducted through the 80 Win platform, including non-face-to-face relationships and intermediary arrangements. It covers onboarding, ongoing activity, and all payment flows processed through 80 Win, including third-party payment services used by customers. The Policy governs activities that present money laundering or terrorist financing risks as determined by a risk-based approach.

Governance and Responsibilities

The ultimate responsibility for 80 Win’s AML policy lies with the Director. The Compliance function is charged with implementing, monitoring, and maintaining AML controls. The Policy and procedures are subject to regular review to reflect regulatory changes and evolving risk, with oversight by the Board. Staff roles, responsibilities, and reporting lines are defined to ensure timely escalation of suspicious activity.

Customer Due Diligence and Identity Verification

80 Win applies risk-based customer due diligence (CDD) at onboarding and throughout the business relationship. Before establishing a business relationship, identity must be satisfactorily verified, and information on the customer’s purpose and intended nature of the relationship must be obtained to determine risk posture. Verification procedures are proportionate to risk and may include enhanced checks for higher-risk profiles.

Identity Verification Documentation

The verification framework relies on three elements: (i) identity verification with a government-issued document; (ii) proof of residential address; and (iii) proof of the payment method or source of funds. Acceptable examples include a valid photo ID (passport, national ID, or driver’s license), a recent utility bill or bank statement showing the customer’s name and address, and documentation evidencing payment method ownership (e.g., card copy with masked numbers, e-wallet account screenshot, or bank statement). In cases where photo-ID is unavailable, alternative documentation may be accepted in accordance with internal procedures and applicable law.

Onboarding and Source of Funds

On onboarding, 80 Win collects information sufficient to identify the customer, assess risk, and determine the appropriate level of ongoing due diligence. The source of funds and, where applicable, source of wealth are requested and reviewed for higher-risk transactions. Documentation requirements may vary by deposit method and are subject to updates in line with evolving payment methods and regulatory expectations.

Ongoing Monitoring and Risk-Based Review

80 Win maintains an ongoing monitoring program to identify and assess money laundering and terrorist financing risks. Customer risk profiles are reviewed at onboarding and then at regular intervals (monthly or as risk dictates). The monitoring process includes updating customer information, reviewing transaction patterns, and adjusting the risk classification as necessary. Material changes in risk or business activity trigger enhanced due diligence or escalation to the compliance function.

Enhanced Due Diligence and High-Risk Scenarios

Enhanced due diligence (EDD) applies where customers or transactions present elevated risk. EDD measures may include additional identity checks, verification of source of funds, higher thresholds for transaction monitoring, enhanced ongoing monitoring, and management-level review. High-risk factors include unusual transaction patterns, high-value activity, and involvement of restricted or high-risk jurisdictions.

Record Keeping and Data Retention

80 Win maintains records of customer identification, risk assessments, transaction data, and due diligence steps for a period consistent with regulatory requirements and internal policy. Records include documentation collected, verification outcomes, and any relevant internal communications related to AML/CFT controls. Information retained is available for inspection by competent authorities in accordance with law and policy.

Reporting of Suspicious Activity and Cooperation with Authorities

80 Win will promptly identify and report suspicious activity to the competent authority in accordance with applicable law. In situations where suspicion arises, the operator may suspend or block account activity, withholding access to funds as required. The operator may disclose customer information and transaction details to regulatory authorities, banks, payment institutions, and other entities as permitted by law, in order to comply with AML/CFT obligations. The operator shall not disclose investigations or ongoing inquiries to the customer where disclosure could impede the investigation.

Training and Internal Controls

All staff receive AML/CFT training appropriate to their role, with periodic refreshers to address changes in regulation, process, or risk. Training covers identification of red flags, escalation procedures, record-keeping requirements, and data protection. Internal controls are reviewed on a periodic basis to ensure effectiveness and to address emerging risks.

Payment Processing and Source of Funds Verification

Verification of a customer’s source of funds and ownership of payment methods is performed commensurate with risk and method of funding. Processing rules include: (a) card payments require verification of ownership and visible card details; (b) e-wallets require evidence linking the account to the customer; (c) bank transfers require corroborating transaction data; (d) crypto transactions require wallet verification and transaction history when applicable. Documentation requirements may be updated to reflect changes in payment methods or regulatory expectations.

Policy Review and Updates

This AML Policy is reviewed at least annually, and more often if required by regulatory changes or substantial business developments. Material amendments are approved by the Board and communicated to customers in accordance with applicable communications policies. Changes take effect in a defined notice period to allow customers to adjust their activities.