1.1. Batery.win is operated by YouGMedia B.V., company number 153269, with registered address at Dr. H. Fergusonweg 1, Curaçao, that is authorized by the Government of Curaçao to conduct gaming operations under auspices of License #365/JAZ (Sub-License Number: GLH-OCCHKTW0707032021 issued on July 7th 2021).
1.2. This Anti-Money Laundering and Counter-Terrorism Financing Procedure (hereinafter "Procedure") outlines the general unified standards and procedures of Anti-Money Laundering (AML), Counter Terrorist Finance (CTF), Counter Fraud Procedures, regulations, Risk-Based approach.
1.3. Money Laundering is the process by which criminals attempt to hide and disguise the true origin and ownership of the proceeds of their criminal activities, thereby avoiding prosecution, conviction and confiscation of the criminal funds. Terrorist financing can be similarly described although the funds used for terrorist financing may in fact be of legitimate origin.
1.4. The ability to launder the proceeds of criminal activity through the financial systems of the world is vital to the success of criminal operations. Money is the lifeblood of terrorist organizations and vital to the mounting of terrorist activity.
1.5. Throughout this policy the term AML and CFT are to be used interchangeably.
1.6. Historically, efforts to combat money laundering concentrated on the activities of the traditional banking sector. However, criminals have responded to the measures taken by banks over recent years. They have invested in other methods of converting illegally obtained money.
1.7. YouGMedia B.V. will always seek to disrupt this activity by cooperating fully with the authorities and reporting all suspicious activity to Financial Intelligence Unit Curaçao.
1.8. All YouGMedia B.V. staff members are responsible for considering the AML manual and understanding responsibilities. All staff members must ensure that YouGMedia B.V. procedures are adhered to and must obtain all documentary evidence as outlined within Procedure. In addition, staff members must ensure that all suspicious circumstances are immediately reported to MLCO.
1.9. All contact with Law Enforcement Agencies will be handled by the MLCO.
1.10. The MLCO is responsible for providing and distributing information and updates to the legislation as and when they occur.
1.11. The Procedure is developed and periodically updated by the MLCO based on the general principles set up by the Company’s Director in relation to the prevention of Money Laundering and Terrorist Financing.
2.1. AML - Anti-Money Laundering.
2.2. CFT - Combating the Financing of Terrorism.
2.3. Money Laundering –
2.3.1. the conversion or transfer of property, in the knowledge that such property is derived from a criminal act or from involvement in such an act, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action.
2.3.2. the concealment or disguise of the true nature, origin, source, location, disposition, movement, rights with respect to, or ownership of property, in the knowledge that such property is derived from a criminal act or from involvement in such an act.
2.3.3. the acquisition, possession or use of property, in the knowledge, at the time of acquisition/transfer, that such property was derived from a criminal act or from involvement in such an act.
2.3.4. preparation attempts to commit and association to commit any of the acts referred to in points 2.3.1., 2.3.2. and 2.3.3. of this paragraph.
2.4. Terrorist financing - the financing and supporting of an act of terrorism and commissioning thereof within the meaning of Terrorist organization.
2.5. Money laundering compliance officer (hereinafter referred as to MLCO) - an officer with sufficient knowledge of the institution’s money laundering and terrorist financing risk exposure and sufficient seniority to take decisions affecting its risk exposure, and who need not, in all cases, be a member of the management board.
2.6. Politically exposed natural person (PEP) means a natural person who is or who has been entrusted with prominent public functions including a head of State, head of government, minister and deputy or assistant minister; a member of Parliament or of a similar legislative body, a member of a governing body of a political party, a member of a Supreme Court, a member of a court of auditors or of the board of a Central Bank; an Ambassador, a Chargé d'Affaires and a high-ranking officer in the armed forces; a member of an administrative, management or supervisory body of a State-owned enterprise; a director, deputy director and member of the board or equivalent function of an international organization, except middle-ranking or more junior officials.
2.7. Unusual monetary operation or transaction - a monetary operation or transaction relating to property, which is suspected of being, directly or indirectly, derived from a criminal act or from involvement in such an act and/or is, suspected of being associated with terrorist financing.
2.8. Customer (client) - a customer, who has the approved age and who participates in a game of chance.
3.1. National regulations Pursuant to the National Ordinance of Money Laundering (1993), money laundering is a criminal offence in Curaçao. Further main national regulations relating to money laundering and terrorist financing are amongst others:
3.2. International regulations As a member of the Financial Action Task Force (www.fatf-gafi.org) and of the Caribbean Financial Action Task Force (www.cfatf-gafic.org), Curaçao is meeting International standards by regularly implementing these standards in its national legislation. On international level, the FATF plays a very important role in the combating of money laundering and the financing of terrorism and proliferation of weapons of mass destruction. The FATF monitors the progress of its members in implementing necessary measures, reviews money laundering and terrorist financing techniques and counter-measures and promotes the adoption and implementation of appropriate measures globally. In performing these activities, the FATF collaborates with other international bodies involved in combating money laundering and the financing of terrorism. In total 34 countries are direct members of the FATF and through regional organizations over 180 countries are connected to the FATF. Subsequently the present policy is a combination of the FATF and local AML/CFT rules and regulations. This ensures a solid, internationally accepted basis regarding AML/CFT. In case local laws and regulations require additional compliance duties, the YOUGMEDIA B.V. is free to develop additional procedures to comply with local regulations
4.1. YouGMedia B.V. designates MLCO who is responsible for organizing the implementation of money laundering and/or terrorist financing prevention measures as specified in the Money Laundering Regulation and for liaising with the Financial Intelligence Unit (FIU) Curaçao.
4.2. Only a person who has the education, professional suitability, the abilities, personal qualities, experience and impeccable reputation required for performance of the duties of a compliance officer may be appointed as a MLCO.
4.3. MLCO obligations include but are not limited to:
4.3.1. establishment of appropriate internal control procedures with the purpose of prevention of monetary operations and transactions related to money laundering and/or terrorist financing: customer and beneficial owner due diligence, submission of reports and information to the Financial Intelligence Unit Curaçao, storage of information according to Money Laundering Regulation, risk assessment, risk management (taking into account the type of product, service or transaction, geographical risk, etc.), compliance management and communication;
4.3.2. undertaking of appropriate measures so that their relevant employees are aware at all times of the provisions currently in force. Such measures shall include participation of the relevant employees in special ongoing training programs to help them recognize operations which may be related to money laundering and/or terrorist financing and provision of instruction to said employees as to how to proceed in such cases.
4.3.3. controlling overall compliance policy for prevention of money laundering and/or terrorist financing and ensuring adequate resources are provided for the proper training of staff and the implementation of risk systems. This includes computer software to assist in oversight.
4.3.4. keeping copies of all training materials. Updated AML training is given annually at minimum plus additional training when the need arises, for example in the case of significant changes in the Legislation. Records must be retained of all training sessions including dates, personnel, who received training (name, surname, functions in the company, their signatures), compliance officer who trained staff (name, surname, functions in the company, their signatures);
4.3.5. monitoring all amendments in the Legislation aimed at prevention money laundering and/or terrorist financing and updating internal instructions according to up-to-date information. The internal instructions must be updated at least once a year.
5.1. For the purpose of identification, assessment and analysis of risks of money laundering and terrorist financing related to their activities, YouGMedia B.V. prepares a risk assessment, taking account of at least the following risk categories:
5.1.1. risks relating to customers.
5.1.2. risks relating to countries, geographic areas or jurisdictions.
5.1.3. risks relating to products, services or transactions.
5.1.4. risk relating to communication, mediation or products, services, transactions or delivery channels between YouGMedia B.V. and customers.
5.2. The steps taken to identify, assess and analyze risks must be proportionate to the nature, size and level of complexity of the economic and professional activities of YouGMedia B.V.
5.3. As a result of the risk assessment, YouGMedia B.V. maintains the following risk classification:
5.3.1. Low risk. All Players are classified as Low risk and are subjected to Standard Due Diligence procedures related to the request for KYC documentation as per the process described above and constant monitoring of activities on the account.
5.3.2. High risk. The Player activity is the determining factor for the classification of a Player as High Risk. Any Player of which an automated alert has been generated or an inappropriate activity has been detected will be categorized as High Risk, for which an Enhanced Due diligence procedure is applied. The instances in which a High risk classification is assigned includes but are not limited to those instances as mentioned in the section below.
6.1. The meaning ‘politically exposed persons’ includes the following natural persons who are or have been entrusted with prominent public functions’ in a foreign country:
6.2. YouGMedia B.V. should pay more attention when the customer originate from a country which is widely known to face problems of bribery, corruption and financial irregularity and whose anti-money laundering laws and regulations are not equivalent with international standards.
6.3. In order to effectively manage such risks, the YouGMedia B.V. assesses the countries of origin of their client in order to identify the ones that are more vulnerable to corruption or maintain laws and regulations that do not meet the 40+9 requirements of the Financial Action Task Force.
6.4. With regard to the issue of corruption one useful source of information is the Transparency International Corruption Perceptions Index which can be found on the website of Transparency International at www.transparency.org. With regard to the issue of adequacy of application of the 40+9 recommendations of the FATF, the Company may retrieve information from the country assessment reports prepared by the FATF or other regional bodies operating in accordance with FATF’s principles (e.g. Moneyval Committee of the Council of Europe) or the International Monetary Fund.
7.1. Standard Due Diligence. The YOUGMEDIA B.V. requests identification and verification of the identity of the Customer (as set forth in paragraph 7).
7.2. Standard Due Diligence is conducted in the following cases:
7.2.1. anytime during the Customer onboarding;
7.2.2. upon a request for withdrawal;
7.2.3. if the value of the Customer’s transactions in a calendar month exceeds 1000 Euro or an equivalent amount in another currency, regardless of whether the financial obligation is executed in a transaction in one payment or several interconnected payments, unless otherwise provided by law.
7.2.4. anytime at the discretion of the YOUGMEDIA B.V.
7.3. YOUGMEDIA B.V. further reserves the right to conduct a phone verification of the Customer Account to verify details provided by the Customer at the time of registration or at any other time requested by the YOUGMEDIA B.V. The adequate timeframe for completion of standard due diligence may vary depending on several factors, such as the volume of documentation provided, the complexity of the verification process, and the workload of the operator's verification team. In general, YOUGMEDIA B.V. aim to complete standard due diligence within a reasonable time frame, which can range from a few hours to a few business days. It's important to note that YOUGMEDIA B.V. is required to comply with regulatory requirements for customer identification and verification, which may affect the time frame for completion of the process. If you have any concerns or questions about the time frame for completion of due diligence, it's recommended to contact customer support team for clarification.
7.4. YOUGMEDIA B.V. further reserves the right to conduct a phone verification of the Customer Account to verify details provided by the Customer at the time of registration or at any other time requested by the YOUGMEDIA B.V.
7.5. Enhanced Due Diligence. In certain specific instances the YOUGMEDIA B.V. will conduct Enhanced Due Diligence by requesting the following KYC information (additionally notwithstanding requirements set forth in paragraph 7):
7.5.1. A selfie of the Customer holding the identification document.
7.5.2. A recently issued utility bill or bank statement.
7.5.3. A bank statement showing the initial deposit.
7.5.4. A bank statement no older than 3 months from the bank to which a withdrawn amount should be deposited.
7.5.5. Information regarding the source of wealth.
7.6. There are also following Enhanced due diligence measures applicable:
7.6.1. receiving and verifying the information about the residential address of the customer.
7.6.2. continuous monitoring of the customer account activity, including tracking transactions conducted during a relationship, regular checking of the data used to identify the person, updating relevant documents, data, and information, and, if necessary, identifying the source and origin of the funds used in the transaction.
7.7. Enhanced Due Diligence is applied as soon as a Customer is classified as a High risk including but not limited to the following situations and as further discussed in the section ‘Monitoring of Account Holder activities:
7.7.1. when there are doubts about the veracity or authenticity of the previously obtained identification data of the Customer.
7.7.2. in any other case, when there are suspicions that the act of money laundering and/or terrorist financing is, has been or will be carried out.
7.7.3. upon suspicion of a Customer attempting to or having created multiple Customer Accounts in multiple different names.
7.7.4. upon suspicion of Customer(s) being part of a syndicate of Customers colluding to gain an advantage over the YOUGMEDIA B.V.
7.7.5. upon suspicion of the Customer being a politically exposed person (PEP).
7.7.6. at the detection of any irregular, suspicious, inappropriate or fraudulent activity.
7.8. The YOUGMEDIA B.V. will process Enhanced Due Diligence within a reasonable timeframe, as specified by the YOUGMEDIA B.V. This timeframe may vary depending on the nature of the information requested and other factors.
7.9. If the YOUGMEDIA B.V. is not able to verify the identity of the Customer based on the provided documentation and further efforts, the YOUGMEDIA B.V. reserves the right to put the Customer Account on hold pending the provision of verification information, or to terminate the account if it finds the information contained in the Customer Account to be false or misleading.
7.10. YOUGMEDIA B.V. employees shall be prohibited from establishing or continuing any relationships and carrying out transactions when it is not possible to fulfil the due diligence requirements established in this procedure:
7.10.1. where, in the cases established by this procedure, the Customer fails to submit the data confirming his identity and his residential address, or where he submits incomplete data;
7.10.2. where the data are incorrect, or where the Customer avoids submitting the information required for establishing his identity or the submitted data are insufficient for that purpose.
7.11. YOUGMEDIA B.V. shall be prohibited from establishing or continue any relationships without requesting the Customer to submit data confirming his identity as per section 6.1., or where there is a substantiated suspicion that the data recorded in these documents are false or falsified.
7.12. In the period of cooperation with the customer YOUGMEDIA B.V. must in all cases:
7.12.1. carry out the ongoing monitoring of the Customer’s activity on his account, used payment methods for refilling his balance and withdrawal transactions, including scrutiny of transactions undertaken throughout the course of such relationships, to ensure that the transactions being conducted are consistent with YOUGMEDIA B.V. knowledge of the customer, risk profile as well as the source of funds.
7.12.2. to ensure that the documents, data or information submitted by the Customer during due diligence are appropriate, relevant, regularly reviewed and kept up to date.
7.13. Customers under 18 are not allowed to register. The system prevents minors from registering by checking on the date for birth. The system does not allow to register USA residents.
7.14. For verification of payment methods used by the customers to add funds to their accounts YOUGMEDIA B.V. may ask:
7.14.1. photo of a credit card(s) used to make the deposit (the front side with the first 6 digits and the 4 last digits, the expiry date, and the name of the card owner all visible, rear side with the CVV covered).
7.14.2. bank statement of the account from which the deposit was made for a period of the last 6 months displaying the name of the account holder.
7.14.3. a screenshot from the personal account of the customer in the payment system displaying the transfer of the funds in favor of YOUGMEDIA B.V. (in case when e-wallet is used for making deposits).
7.14.4. if the Customer’s preferred method of adding the funds to his account is through his e-wallet, where funds can be added only by wire transfer or credit card, YOUGMEDIA B.V. may additionally ask to provide an account statement of the credit institution confirming the origin of the deposit.
7.14.5. if the Customer is adding funds to his account using other payment, YOUGMEDIA B.V. may ask to prove of the legitimacy of funds used for the deposit.
7.14.6. YOUGMEDIA B.V. may ask for a screenshot from a personal e-wallet account to confirm the name of the account holder.
7.15. YOUGMEDIA B.V. may, in accordance with internal policies and internal control procedures, refuse to execute the monetary operations or transactions and terminate the transactions or relationship with the Customer, where the customer avoids submitting, or refuses to submit, additional information to a YOUGMEDIA B.V., at its request and within the specified time limits.
8.1. YOUGMEDIA B.V. identifies the Customer and retains the following data prior to account opening:
8.1.1. first name, surname.
8.1.2. personal identification code or, in the absence of a personal identification code, date of birth, place of birth, and
8.1.3. a residential address.
8.2. YOUGMEDIA B.V. verifies the identification data specified in clauses 8.1.1. and 8.1.2 based on a valid official identity document which includes a photograph of the holder:
8.2.1. driving license.
8.2.2. identity card.
8.2.3. travel-document or passport.
8.2.4. any other document designated by the Ministry of Finance.
8.3. The verification of the residential address may be carried out based on the following documents:
8.3.1. valid official identity document.
8.3.2. recent utility bill.
8.3.3. recent account statement or reference letter issued by a credit institution/financial institution.
8.3.4. correspondence from a central or local government authority, department or agency.
8.3.5. any other documents issued by independent agency.
8.4. In case the employees of YOUGMEDIA B.V. have suspicions about the Customer’s identity document specified in section 8.2., they may ask to provide the copy of the identity document authenticated by a notary or certified by a notary.
9.1. YOUGMEDIA B.V. must pay attention to any activity which they regard as likely, by its nature, to be related to money laundering and/or terrorist financing, and in particular to complex or unusually large transactions, and all unusual patterns of transactions which have no apparent economic or visible lawful purpose, and any relationships or monetary operations with customers from third countries in which, based on the information officially published by international intergovernmental organizations, money laundering and/or terrorist financing prevention measures are insufficient or do not correspond to international standards. YOUGMEDIA B.V. must examine the basis for and purpose of execution of such operations or transactions and the results of the investigation must be recorded in writing.
9.2. MLCO must report to the Financial Intelligence Unit Curaçao any suspicious or unusual monetary operations or transactions.
9.3. Suspicious or unusual monetary operations or transactions, including:
9.3.1. cases where it is aware of, obtains information concerning, has suspicions or has substantial grounds to suspect that money laundering and/or terrorist financing was, is, or will be performed, or it has been attempted.
9.3.2. cases where they have a suspicion or sufficient grounds to suspect that the customer’s funds have been obtained from criminal activity.
9.3.3. cases where they have a suspicion or sufficient grounds to suspect that the transactions or activities are related to terrorist financing.
9.4. There are indicators helping to identify unusual transactions. Indicators describe when a transaction (executed or intended) is to be labeled as unusual, and thus should be reported to the Financial Intelligence Unit Curaçao.
9.5. There are two kinds of indicators: objective and subjective:
9.5.1. in case of an objective indicator (see the Annex 1), it describes mandatory under which circumstances a transaction is to be considered as unusual.
9.5.2. in case of a subjective indicator (see the Annex 1), the transaction is considered unusual if the reporting entity (based on its knowledge of its clients, their income and their business activities, and any other circumstance that may be relevant) has reasonable indications to presume that a transaction is related to money laundering or terrorism financing. For subjective indicators, red flags can be suggested by the supervisors and/or the FIU Curaçao that indicate such possible presumptions.
9.6. MLCO must report about unusual monetary operations or transactions mentioned in section 9.3. without delay to the Financial Intelligence Unit Curaçao.
9.7. The term "without delay" is interpreted as follows:
9.7.1. MLCO should send unusual transaction reports within 48 hours after the transaction has been executed, or after there has been an intention of a transaction.
9.7.2. In individual cases the reporting to Financial Intelligence Unit Curaçao might be extended to a maximum of 5 working days. A request for extended reporting should be directed in writing to the Financial Intelligence Unit Curaçao, stating the reasons for the extension.
9.7.3. The Financial Intelligence Unit Curaçao will inform the respective reporting entity in writing of its decision within 24 hours.
9.7.4. The time period between the execution of the transaction (or the intention to execute a transaction) and the moment the MLCO receives the report, should not exceed 24 hours.
9.7.5. As of the moment that the MLCO receives the transaction report, he has to complete the relevant research with regard to a possible Money Laundering/Terrorism Financing within 10 working days.
9.7.6. If after the research period (maximum of 10 working days), there is a suspicion of Money Laundering/Terrorism Financing, the MLCO must report the transaction within 48 hours to the Financial Intelligence Unit.
9.7.7. In the case it is not possible to comply with the above-mentioned time periods, the MLCO shall send a request for reporting extension in writing to the Financial Intelligence Unit Curaçao, stating the reasons for this extension.
9.7.8. The Financial Intelligence Unit Curaçao will evaluate objective grounds and inform the reporting entity on its decision in writing within 48 hours upon receiving the request.
9.8. A report to the FIU is submitted via GoAML reporting portal (link to register in GoAML - http://mot.cw/Web/MOTWeb/MOTWeb.nsf/web/goaml%20the%20new%20portal%20for%20fiu%20curacao).
9.9. The structural unit of YOUGMEDIA B.V., a member of a management body and an employee are prohibited to inform a person about a report submitted on them to the Financial Intelligence Unit, a plan to submit such a report or the occurrence of reporting as well as about any precept made by the Financial Intelligence Unit or about the commencement of criminal proceedings.
9.10. The prohibition provided for in section 8.9. is not applied upon submission of information to competent supervisory authorities and law enforcement agencies.
9.11. YOUGMEDIA B.V. shall establish a system of measures ensuring that the employees and representatives of the entity reporting of a suspicion of money laundering or terrorist financing to the Financial Intelligence Unit are protected from being exposed to threats or hostile action by other employees, management body members or customers of YOUGMEDIA B.V., in particular from adverse or discriminatory employment actions.
10.1. YOUGMEDIA B.V. must keep a register of reports of unusual monetary operations and transactions specified in section 8.3. of this procedure.
10.2. YOUGMEDIA B.V. must keep a register of the customers with whom transactions or relationships were terminated under the circumstances specified in section 6.6. of this procedure or under any other circumstances related to violations of the procedure for the prevention of money laundering and/or terrorist financing.
10.3. Register data shall be stored in paper or electronic format for five years from the date of termination of transactions or relationships with the customer.
10.4. Copies of the identity documents of the customer, other data received at the time of establishing the identity of the customer must be stored for five years from the date of termination of transactions or relationships with the customer.
10.5. The correspondence with the customer must be stored in paper or electronic form for five years from the date of termination of transactions or relationships with the customer.
10.6. Time limits for storage may be additionally extended upon receipt of a reasonable request from a competent institution.
10.7. YOUGMEDIA B.V. must store the personal data of staff referred to in section 10.4. of this procedure for five years upon termination of employment.
11.1. In providing the specified categories of employees with the AML/CTF training, YOUGMEDIA B.V. shall take into consideration the knowledge and qualifications necessary for the duties, responsibilities and authorization of staff. YOUGMEDIA B.V. shall, within the framework of the training, explain to staff the AML/CTF requirements and provide detailed information on the measures and activities the staff are expected to conduct within the framework of their responsibilities.
11.2. YOUGMEDIA B.V. shall develop and document a staff training plan which contains at least the following programs:
11.2.1. an internal training program for staff, which uses internal training resources (hereinafter referred to as the “internal training”).
11.2.2. a training program for new employees (employees who have just started to perform their duties or changed position at YOUGMEDIA B.V. (hereinafter referred to as the “new staff training”).
11.3. In addition to the internal training program referred to in subsection 11.2.1. of the present Regulations, YOUGMEDIA B.V. shall ensure extraordinary staff training in the cases referred to in section 11.6. of this procedure.
11.4. YOUGMEDIA B.V. shall ensure that the information on the conducted staff training is saved by documenting the following data:
11.4.1. name of the training.
11.4.2. personal data of the trained employee.
11.4.3. position and structural unit of the trained employee.
11.4.4. training venue.
11.4.5. head and organizer of the training.
11.4.6. time of training.
11.4.7. duration of the training.
11.4.8. result of knowledge tests and certificate obtained, if any.
11.5. YOUGMEDIA B.V. shall ensure that, in addition to the internal and external training, any employee may obtain the necessary advice from senior employees involved in the AML/CTF risk management.
11.6. In addition to the internal training, YOUGMEDIA B.V. shall ensure extraordinary staff training in AML/CTF issues at least in the following cases:
11.6.1. new internal and external regulations governing the AML/CTF have come into force and are applicable to the staff of YOUGMEDIA B.V.
11.6.2. new services have been introduced which cause changes in the AML/CTF risk exposure.
11.6.3. during performance of his/her duties an employee violates the internal and external regulations governing the AML/CTF due to insufficient knowledge.
Objective indicators
A. A transaction which is reported to the police or judicial authorities
| Indicator | Definition |
|---|---|
| G0000111 | A transaction which is reported to the police or judicial authorities in connection with money laundering or the financing or terrorism. |
B. An intended transaction carried out by or for the benefit of a natural person, legal person, group or entity which is on a list compiled by virtue of the Sanctions National Ordinance.
| G0000114 | An intended transaction carried out by or for the benefit of a person, legal person, group or entity that is mentioned on a list compiled in pursuance of the Sanctions National Ordinance. |
C. A transaction amounting to NAF (ANG) 5,000.00 or more, regardless whether this transaction is carried out in cash, via a check or another payment instrument or electronically or in any other non-physical manner; This comprises in any case the following situations:
| G0000135 | 1. A giro-based transaction amounting to NAF (ANG) 5,000.00 or more: |
| A giro-based transaction is a transfer from a bank account of the service provider to a local or international bank account carried out at the request of the client addressed to the service provider. | |
| 2. The taking into deposit or the releasing out of deposit of an amount of NAF(ANG) 5,000.00 or more, at the request of the client. | |
| 3. Sale of tokens to a client in the amount of NAF (ANG) 5,000.00 or more. | |
| The term "tokens" includes at least chips and credits. | |
| 4. Pay-out of prizes in the amount of NAF (ANG) 5.000,-- or more. | |
| 5. All other cases. | |
| NB In case of Indicator G0000135: please also indicate the applicable sub-indicator (1,2,3,4 or 5) when reporting a transaction. In case of sub-indicator 5, please always provide a description of the situation. |
Subjective indicator Suspected money laundering transactions or financing of terrorism.
| Indicator | Definition |
|---|---|
| G0000211 | A transaction giving cause to assume that it may be connected with money laundering or terrorist financing. |
The following applies for all indicators in these annexes:
Last modified: 20 Jan 2023