KYC Policy

KYC Policy of Play and Fun Ltd.

Last updated: 28.05.2024

Introduction

https://club365.vip is operated by Play and Fun Ltd., a limited liability company registered in Island of Anjouan, Union of Comoros, with company registration number 15689, with registered address at Hamchako, Mutsamudu, the Autonomous Island of Anjouan, Union of Comoros (“Company”), licensed in State of Anjouan under the Computer Gaming Licensing Act 007 of 2005.

The objective of the AML Policy: We seek to offer the highest security to all of our users and customers on https://club365.vip; for that, three-step account verification is done to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into the accord that depending on the nationality and origin, the way of payment, and withdrawal, different safety measures must be taken.

https://club365.vip also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

https://club365.vip is committed to high standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) according to the EU guidelines and compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of https://club365.vip 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 money laundering.”
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

Definition of money laundering

Money Laundering is understood as:

The conversion or transfer of property, especially 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 helping any person who is involved in the commission of such an activity to evade the legal consequences of that people or companies action;
The concealment or disguise of the true nature, source, location, disposition, movement, and 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 to aid, to abet, facilitate, and counseling the commission of any of the actions referred to in points before.

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/CTF forhttps://club365.vip

Following the AML/CTF legislation, https://club365.vip has appointed the “highest level” for the prevention of ML: The entire management of Play and Fun Ltd. is in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.

The AMLCO is placed under the direct responsibility of the general management.

AML policy changes and implementation requirements

Each significant change of https://club365.vip AML policy is subject to approval by the general management of Play and Fun Ltd. and the Anti-money laundering compliance officer.

Three step Verification

Step 1 verification:

Every user and customer must do step one verification to withdraw. Regarding the choice of payment, the amount of payment, the amount of withdrawal, the option of withdrawal, and the nationality of the user/customer, step one verification must be done first. Step one verification is a document that the user/customer himself must fill out. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender, and full address.

Step 2 verification:

Step two verification must be done by every user who deposits over 2000$ (two thousand Dollars) or withdraws over 2000$ (two thousand dollars). Until step two verification is done, the withdrawal or deposit will be on hold. Step to validation will lead the user or customer to a subpage where he must send in his ID. The user/customer must make a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification; depending on the country, the variety of accepted IDs may be different. There will also be an electronic check if the filled-in Data from the step one verification is correct. The electronic check will check via two various databanks to ensure the given information matches with the filled document and the name from the ID: If the electronic test fails or is not possible, the user/customer is required to send in confirmation of his current residence. A certificate of registration by the government or a similar document is required.

Step 3 verification:

Step three verification must be done by every user who deposits over 5000$ (five thousand Dollars) or withdraws over 5000$ (five thousand Dollar). Until step three verification is done, the withdrawal or deposit will be on hold. For step 3, a user/customer will be asked for a source of wealth.

Customer identification and verification (KYC)

The Company adheres to and complies with “Know your customer” principles, which aim to prevent financial crime and money laundering through client identification and due diligence.

The Company reserves the right, at any time, to ask for any KYC documentation it deems necessary to determine the identity and location of a user in https://club365.vip We reserve the right to restrict the service, payment, or withdrawal until identity is sufficiently determined, or for any other reason in our sole discretion based on the legal framework.

We take a risk-based approach and perform strict due diligence checks and ongoing monitoring of all clients, customers, and transactions. As per the money laundering regulations, we utilize three stages of due diligence checks, depending on the risk, transaction, and customer type.

SDD — simplified due diligence is used in instances of extremely low-risk transactions that do not meet the required thresholds

CDD — customer due diligence is the standard for due diligence checks, used in most cases for verification and identification

EDD — Enhanced Due Diligence is used for high-risk customers, large transactions or special cases.

Basic document for step one

The primary document will be accessible via the setting page on https://club365.vip . Every user has to fill out the following information:

First name
Second name
Nationality
Gender
Date of Birth

The document will be saved by an AI and stored during the period of five years; an employee may do additional checks if necessary based on the situation.

Separately and in addition to the above, when a user makes an aggregate lifetime total of deposits exceeding EUR 5,000 or requests a withdrawal of any amount inside the https://club365.vip, or attempts to or completes a transaction that is deemed suspicious, then it is compulsory for them to complete the full KYC process.

During this process, the user will have to input some basic details about themselves and then upload:

1) A copy of Government Issued Photo ID (in some cases front and back depending on the ID document)

2) A selfie of themselves holding the ID doc

3) A bank statement/Utility Bill

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 six randomly generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information besides the date of birth, nationality, gender, first name, second name, and picture. To secure their privacy.

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 names above. We might ask for all details if necessary.

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

Proof of Address

Proof of address will be done via different electronic checks, which use two different databases. If an electronic test fails, the user/customer has the option to make a manually proof.

A recent utility bill sent to your registered address, issued within the last three months, or an official document made by the government that proves your state of residence.

To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document are visible and all text is readable.

For example, an electricity bill, water bill, bank statement, or any governmental post addressed to you.

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

Source of funds

If a player deposits over five thousand euros, there is a process of understandings the source of wealth (SOW)

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 proof.

The account will be frozen if the same user deposits either this amount in one go or multiple Sanctions

which amount to this. An email will be sent to them manually to go through the above and information on the website itself.

https://club365.vip also asks for a bank wire/credit card to further ensure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

Guideline for the “KYC Process”

1) Proof of ID

Signature Is there
Country is not one of the following Restricted Countries:

Austria
France and it’s territories
Germany
Netherlands and it’s territories
Spain
Union of Comoros
United Kingdom
USA and it’s territories
All FATF Blacklisted countries
Countries being subject to sanctions, embargoes or similar measures
any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority.

Full Name matches client’s name
Document does not expire in the next 3 months
Owner is over 18 years of age

2) Proof of Residence

Bank Statement or Utility Bill
Country is not one of the following Restricted Countries:

Austria
France and it’s territories
Germany
Netherlands and it’s territories
Spain
Union of Comoros
United Kingdom
USA and it’s territories
All FATF Blacklisted and countries
Countries being subject to sanctions, embargoes or similar measures
any other jurisdictions deemed prohibited by Anjouan Offshore Financial Authority.

Full Name matches client’s name and is same as in proof of ID.
Date of Issue: In the last 3 months

3) Selfie with ID

Holder is the same as in the ID document above
ID document is the same as in “1”. Make sure photo/ID number is the same

Risk management

To deal with the different country risks and different states of wealth in other regions on the earth https://club365.vip will categorize every nation into three distinct regions of risk.

Region one: Low risk

For every nation from region one, the three-step verification is done as described earlier.

Region two: Medium risk

For every nation from region two, the three-step verification will be done at lower deposit, withdrawal, and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000$ (one thousand dollars) and withdrawing 1000$ (one thousand Dollars). Step three will be done after depositing 2500$ (two thousand five hundred dollars) and withdrawing 2500$ (two thousand five hundred dollars). Also, users from a low-risk region that change the cryptocurrency to any other currency will be treated like users/customers from a medium-risk region.

Region three: High risk

Regions of high risk will be banned. High-risk regions will be regularly updated to keep up with the changing environment of a fast-changing world. A jurisdiction may be classified as higher risk due to it being subject to sanctions, embargoes or similar measures. It can also be identified by the Financial Action Task Force (“FATF”) as non-cooperative in the fight against money laundering, or identified by credible sources as lacking appropriate money laundering laws and regulations. The jurisdiction is also identified by credible sources as providing funding or support for terrorist activities or having significant levels of corruption, or being a non- transparent tax environment.

Additional measurements

In addition, an AI that the AML compliance officer oversees will look for any unusual behavior and report it right away to an employee of https://club365.vip.

According to a risk-based few and broad experience, the human employees will recheck all checks which are done bevor by the AI or other employees and may redo or do additional reviews according to the situation.

In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behavior like Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account for Deposit and Withdraw, nationality changes, currency changes, behavior and activity changes, as well as checks, if an account is used by its original owner.

Also, a user has to use the same method for Withdraw as he used for Deposit for the amount of the Initial Deposit to prevent any Money Laundering.

Politically Exposed Persons (PEP)

Much international attention has been paid in recent years to the risk associated with providing financial and business services to those with prominent political profile or holding senior public office. However, PEP status itself does not automatically mean that the individuals are corrupt or that they have been incriminated in any corruption.

However, their office and position may render PEPs vulnerable to corruption. The risks increase when the person concerned is from a foreign country with widely known problems of bribery, corruption and financial irregularity within their governments and society. This risk is even more acute where such countries do not have adequate AML/CFT standards.

PEP is a person who holds or has held one of the following offices or positions in or on behalf of a country:

head of state or head of government;
member of the executive council of government or member of a legislature;
deputy minister or equivalent rank;
ambassador, or attaché or counsellor of an ambassador;
military officer with a rank of general or above;
president of a state-owned company or a state-owned bank;
head of a government agency;
judge of a supreme court, constitutional court or other court of last resort; or
leader or president of a political party represented in a legislature.

PEP determination will be done via self-determination of user and also a PEP search that covers global and adverse media lists. The number of sources and how often the information is updated should be considered.

In the event a player is determined to be a PEP or a family member or close associate of a PEP, we will end business relationships immediately.

Enterprise-wide risk assessment

As part of its risk-based approach, https://club365.vip has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to https://club365.vip and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines, such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and commerce, and other qualitative and emerging risks.

The identification of AML risk categories is based on https://club365.vip understanding of regulatory requirements, regulatory expectations, and industry guidance. Additional safety measures are taken to take care of the other risks the world wide web brings with it.

The EWRA is yearly reassessed.

Ongoing transaction monitoring

AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions that are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on two levels:

1) The first Line of Control:

https://club365.vip works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent the large majority of suspicious deposits onto https://club365.vip from taking place without proper execution of KYC procedures onto the potential customer.

2) The second Line of Control:

https://club365.vip makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular, these include:

Requests for the execution of financial transactions on the account;
Requests concerning means of payment or services on the account.

Also, the three-step verification with adjusted risk management should provide all necessary information about all customers of https://club365.vip at all times.

Also, all transactions must be overseen by employees overwatched by the AML compliance officer, who the general manager overwatches.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager, must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment concerning the knowledge of the customer (KYC), their financial behavior, and the transaction counterparty.

These checks will be done by an automated system, while an Employee crosschecks them for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must, therefore, rapidly be considered atypical (as they are not directly justifiable).

Any https://club365.vip staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known to the customer.

3) The third Line of Control:

As the last line of defense against AML https://club365.vip will do manual checks on all suspicious and higher-risk users to entirely prevent money laundering.

If fraud or Money Laundering is found, the authorities will be informed.

Reporting of Suspicious transactions on https://club365.vip

In its internal procedures, https://club365.vip describes in precise terms the attention of its staff members, when it is necessary to report and how to proceed with such reporting.

Reports of atypical transactions are analyzed within the AML team following the precise methodology fully 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, by 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.

Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the Intranet site of https://club365.vip.

Record keeping

Records of data obtained for identification must be kept for at least ten years after the business relationship has ended.

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

These data will be safe and encrypted, stored offline and online.

Training

https://club365.vip human employees will make manual controls on a risk-based approval for which they get special training.

The training and awareness program is reflected by its usage:

A mandatory AML training program following the latest regulatory evolutions for all in touch with finances
Academic AML learning sessions for all new employees

The content of this training program has to be established by the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML specialist working in the Play and Fun Ltd. AML team.

Data Security

All data given by any user/customer will be kept secure and will not be sold or provided to anyone else. Only if forced by law or to prevent money laundering data may be shared with the AML authority of the affected state.

https://club365.vip will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

Contact us

If you have any questions about our AML and KYC Policy, please get in touch with us by email: [email protected]

If you have any complaints about our AML and KYC Policy or the checks done on your Account and your Person, please get in touch with us by email: [email protected] .