Betwinner is committed to preventing money laundering and the financing of terrorism. This Anti‑Money Laundering Policy (the Policy) sets out the framework by which Betwinner detects, deters and reports suspicious financial activity in connection with its betting and gaming services. The Policy applies to all Betwinner personnel, contractors, agents, and any entity acting on Betwinner’s behalf, including payment processors and affiliates, and covers all products and services offered by Betwinner.
Betwinner operates in compliance with applicable AML/CFT laws and regulations in its licensing jurisdiction and with internationally recognized standards. For purposes of this Policy, the following terms have the meanings set out below: money laundering means the process by which illicit funds are converted into legitimate assets; financing of terrorism refers to activities that fund or facilitate terrorist acts; customer due diligence (CDD) is the process of verifying a customer’s identity and assess the risk they pose; enhanced due diligence (EDD) is intensified verification and monitoring for higher‑risk customers or transactions; ongoing due diligence means continual monitoring of a customer relationship and its transactions; and a suspicious activity report (SAR) is a report made to the competent authority when activities indicate potential money laundering or terrorist financing.
Betwinner maintains an AML Compliance Program overseen by a designated AML Compliance Officer who reports to the executive leadership and the board. The Policy, and related procedures, are reviewed at least annually or more frequently in response to regulatory changes or material risk events. Independent testing of controls may be conducted by qualified third parties as part of the audit cycle.
Betwinner conducts ongoing transaction monitoring to identify suspicious activity. Automated rule sets flag patterns such as: a single deposit or transfer above €3,000; cumulative deposits within a 24‑hour window exceeding €5,000; rapid cyclical deposits and withdrawals; or funds inconsistent with the customer’s known profile. When suspicious activity is identified, the matter is escalated to the AML Compliance Officer for assessment. If warranted, Betwinner will file a SAR with the competent authority promptly and no later than 24 hours from initial identification, while maintaining appropriate confidentiality and without tipping off the customer where prohibited by law.
Betwinner screens customers against applicable sanctions lists and publicly available adverse information, and it applies enhanced controls for Politically Exposed Persons (PEPs) and customers located in high‑risk jurisdictions. When screening identifies a potential risk, Betwinner applies targeted measures, including enhanced due diligence, ongoing monitoring, and, where necessary, limitation or termination of business relationships in compliance with applicable law.
Betwinner maintains all required customer due diligence records, transaction data, and relevant correspondence for a minimum of five (5) years from account closure or last active date, whichever is later. Records are stored securely and are accessible to regulators and auditors in accordance with applicable law. Where retention requirements exceed this period, Betwinner shall comply with the longer period mandated by law.
Betwinner processes personal data in compliance with applicable data protection laws. Personal information is collected for purposes including identity verification, processing payments, risk assessment, and communication related to Betwinner’s services. Data is maintained by Betwinner as data controller and may be shared with service providers under appropriate data processing agreements. Betwinner will provide information on data subjects’ rights, ensure lawful bases for processing, and implement technical and organizational safeguards. Transfers of personal data comply with applicable cross‑border transfer rules and security standards.
Betwinner provides AML training to all staff upon hire and at least annually thereafter, covering identification of red flags, escalation procedures, and data protection obligations. Training records are retained for inspection by regulators as required.
Betwinner cooperates with competent authorities and law enforcement in AML/CFT investigations. All internal reports of suspicious activity are treated as confidential. Betwinner maintains an auditable trail of all reporting, investigations, and remediation actions. Staff must not disclose, or otherwise tip off, customers or third parties about an ongoing investigation or reporting decision unless legally required.
Customers must provide accurate information during onboarding and update Betwinner promptly if information changes. Customers must provide credible source‑of‑fund documentation when requested and conduct activities consistent with stated purpose. Betwinner reserves the right to suspend or terminate accounts, limit activity, or refuse services where verification cannot be completed, funds originate from illicit activity, or where the customer poses an AML/CFT risk that cannot be mitigated.
This Policy is reviewed at least annually or as required by regulatory changes. Substantive updates are approved by Betwinner’s Board and communicated to customers where appropriate. A versioning log is maintained for regulatory review and evidence of compliance.
Betwinner recognizes the interrelation between AML/CFT controls and responsible gaming. Self‑exclusion tools and responsible gaming features are available to prevent problematic gambling behaviors. Transactions associated with self‑excluded accounts are blocked in accordance with policy and local regulatory requirements.