ANTI-MONEY LAUNDERING (AML) POLICY

1. INTRODUCTION

Select Punters Limited ("the Company") is committed to preventing money laundering, terrorist financing, and other illicit financial activities. As a company operating  the proprietary gaming model (PGM) within the sports betting industry, we recognize the risks associated with financial crimes and aim to implement strict controls to mitigate them.

Money laundering poses significant threats to the integrity of financial systems and the reputation of businesses. It involves disguising illegally obtained funds as legitimate income, often using complex transactions to avoid detection. Given the nature of online gaming and sports betting, there is an increased risk of funds being misused for illicit activities, including fraud, tax evasion, and financing of criminal enterprises. Therefore, this policy establishes the necessary procedures and controls to detect, prevent, and report money laundering activities within our operations.

2. PURPOSE

The purpose of this policy is to:

  • Establish a robust framework for detecting, preventing, and reporting money laundering and terrorist financing activities. This ensures that Select Punters Limited operates within the boundaries of the law and maintains a strong ethical foundation.
  • Ensure compliance with applicable AML regulations and industry best practices. Compliance with international and local regulations safeguards the company from legal repercussions and financial penalties.
  • Protect the integrity of Select Punters Limited’s operations and reputation. A strong AML policy helps build trust with customers, regulatory bodies, and financial institutions.
  • Foster a culture of transparency, accountability, and regulatory adherence. All employees, stakeholders, and customers should understand and support the company’s commitment to financial security and ethical operations.

3. SCOPE

This policy applies to:

  • All employees, contractors, and third-party service providers of Select Punters Limited. Anyone involved in the company’s operations must adhere to AML regulations.
  • Customers and users engaging with Select Punters Limited’s platform. Players utilizing the company’s services must comply with identity verification and anti-money laundering measures.
  • All transactions conducted through our platform, including  evaluations enrollment, and profit-sharing. Every financial activity is subject to monitoring to detect potential money laundering or fraudulent schemes.

4. RISK-BASED APPROACH

Select Punters Limited employs a risk-based approach (RBA) to AML compliance, ensuring that resources are allocated efficiently to areas of higher risk. This means we:

  • Identify and assess risks related to money laundering and terrorist financing. Risk factors include transaction size, customer profile, jurisdiction, and subscription patterns.
  • Implement proportionate risk-mitigation measures. High-risk users or transactions are subject to additional scrutiny, while low-risk transactions undergo routine checks.
  • Conduct ongoing monitoring and reviews of transactions and customer behavior. Continuous evaluation helps identify anomalies that may indicate financial crimes.

5. CUSTOMER DUE DILIGENCE (CDD)

5.1. Identity Verification

Before establishing a business relationship with any customer, Select Punters Limited requires:

  • Full legal name, date of birth, and residential address. These details ensure the legitimacy of the customer.
  • A valid government-issued identification document (e.g., passport, national ID, or driver’s license). This helps prevent identity fraud and unauthorized transactions.
  • Proof of address (e.g., utility bill or bank statement not older than three months). This ensures customers are traceable and accountable.

5.2. Enhanced Due Diligence (EDD)

For customers identified as higher risk, we apply Enhanced Due Diligence (EDD), which may include:

  • Additional identity verification checks. This may involve biometric authentication or secondary forms of identification.
  • Source of funds and wealth verification. Customers may be required to demonstrate the origin of their funds to prevent money laundering.
  • Close monitoring of transactions. High-risk customers will have their transactions reviewed in real time to detect suspicious patterns.
  • Periodic reviews of customer profiles. Customers categorized as high-risk will undergo regular assessments to ensure ongoing compliance.

6. TRANSACTION MONITORING

We implement a robust transaction monitoring system to detect and prevent suspicious activities. Our monitoring measures include:

  • Automated flagging of high-risk transactions. Transactions exceeding certain thresholds or exhibiting unusual patterns will trigger alerts.
  • Pattern recognition for unusual evaluating behaviors. This includes incessant enrollment to evaluation accounts
  • Reviewing transactions involving high-value enrollment. Customers attempting to move large sums through our platform via evaluation enrollment / subscription  must provide justification.
  • Reporting suspicious activities to the appropriate authorities. If any transaction raises red flags, it is escalated for further investigation and, if necessary, reported to regulatory bodies.

7. REPORTING AND RECORD-KEEPING

7.1. Suspicious Activity Reporting (SAR)

Employees are required to report any suspicious transactions or activities to the designated AML Compliance Officer (AMLCO). Suspicious transactions may include:

  • Unusual evaluation enrollment patterns that do not align with the customer’s historical behavior. A sudden shift in evaluation strategy or risk appetite may indicate illicit activities.
  • Transactions involving high-risk jurisdictions. Countries known for weak financial regulations pose a higher risk of financial crimes.

7.2. Record-Keeping Requirements

Select Punters Limited maintains all AML-related records for at least five (5) years, including:

  • Customer identification records. All documents used for identity verification are stored securely.
  • Transaction logs and audit trails. This ensures transparency and enables regulatory compliance checks.
  • Reports submitted to regulatory bodies. All SARs and compliance reports are archived.
  • Internal AML training records. Proof of employee training sessions and compliance adherence is documented.

8. AML COMPLIANCE OFFICER (AMLCO)

Select Punters Limited appoints a dedicated AML Compliance Officer responsible for:

  • Overseeing the implementation and enforcement of this policy. Ensuring that all employees and operations align with AML standards.
  • Liaising with regulatory authorities and reporting suspicious transactions. Communicating with financial regulators to maintain transparency.
  • Conducting periodic AML risk assessments. Evaluating the effectiveness of AML controls and adjusting as needed.
  • Ensuring ongoing training for employees on AML compliance. Keeping staff informed of evolving financial crime risks and regulatory changes.

9. TRAINING AND AWARENESS

All employees undergo mandatory AML training, which includes:

  • Understanding money laundering and terrorist financing risks. Employees learn how criminals attempt to exploit financial systems.
  • Identifying suspicious transactions and customer behaviors. Training sessions provide case studies and red flag indicators.
  • Reporting obligations and escalation procedures. Staff are educated on how and when to report suspected financial crimes.
  • Compliance with relevant AML regulations. Employees are updated on local and international AML laws.

10. THIRD-PARTY DUE DILIGENCE

Select Punters Limited conducts due diligence on third-party service providers, including payment processors and business partners, to ensure they adhere to AML standards. Agreements with third parties must include AML compliance clauses and monitoring mechanisms.

11. REGULATORY COMPLIANCE

We ensure compliance with all relevant AML laws and cooperate fully with regulatory authorities. Our AML framework is subject to regular audits and updates to align with evolving legal requirements.

12. CONSEQUENCES OF NON-COMPLIANCE

Non-compliance with this policy may result in disciplinary actions, termination of employment or business relationships, and potential legal consequences. Customers found engaging in money laundering activities will be reported to the authorities and banned from using our platform.

13. POLICY REVIEW

This policy is reviewed annually or as required by regulatory changes. Updates are communicated to all employees and relevant stakeholders.

14. CONCLUSION

Select Punters Limited is committed to fostering a secure and compliant gaming environment. By adhering to this AML policy, we protect our platform, customers, and stakeholders from financial crime risks while maintaining regulatory integrity.