Anti-Money Laundering (AML) Policy

Winaday Entertainment S.A. (the “Company”) is licensed and regulated by Union of Comoros to offer remote (online) games on the internet, under the License Number L21268. Under the license conditions, the Company is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing, or any other criminal activity.

The Company is fully committed to constant vigilance in order to prevent money laundering and combat the financing of terrorism. The Company minimizes and manages the risks to its reputation, legalities, and regulation. The Company is also committed to its social responsibility of preventing serious crime, with no tolerance of our systems being abused in furtherance of these crimes.

1. Company Policy

Money laundering is the illegal process of concealing the origins of money obtained illegally by passing it through a complex sequence of banking transfers or commercial transactions.

The Company’s policies, procedures, and internal controls are designed to ensure compliance with all applicable laws, rules,directives, and regulations relevant to the Company’s operations. These will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place.

The Company has a designated Money Laundering Reporting Officer (“MLRO”). The MLRO has full responsibility for the AML program. The MLROs will ensure that appropriate training and awareness is provided to new and existing staff, and that this is reviewed and updated as required. The MLROs will ensure that appropriate anti-money laundering systems and processes are incorporated by the Company.

2. Player Identification Program

The Company undertakes reasonable steps to establish the identity of any person for whom it is proposed to provide its service (hereinafter “Player”). For this purpose the process for the registration of the Player under the General Terms and Conditions of the Company provides data for the KYC and due diligence processes of each user account.

The Company collects minimum identification information from each Player who opens a user account. The Company does not allow Players to open anonymous accounts or accounts in fictitious names, such that the true ultimate beneficial owner is not known. The information required will include at least:

a) Player’s date of birth (showing that the player is of legal age);
b) Player’s first and last name;
c) Player’s place of registered residence;
d) Player’s financial information; details of payment cards or other payment channels;
e) Player’s valid and confirmed email address;
f) Player’s valid phone number;
g) Player’s unique username and a password; and
h) IP addresses, cookies, and other online tracking information.

Documents to verify the identity received are requested from the Player if and when there is considered to be risk or uncertainty about the information provided, and prior to any payment in excess of USD 2,000 (per occasion or when payments to the account are made in excess of USD 2,000).

These documents shall include, to the extent permitted under the relevant data protection regulations:

a) A copy of a valid identity card, driving license, or passport;
b) Proof of address, usually in the form of utility bill, no older than three months;

The Company may supplement the use of documentary evidence by using other means which may include:

a) Independently verifying the Player’s identity through the comparison of information provided by the Player with information obtained from any reporting agency, any public database, or any other source;
b) Checking references with financial institutions; or
c) Obtaining the copy of the financial statements.

To this extent the Company utilizes external fully certified verification platforms and compliance services to verify the Player’s true identity.

Any employee of the Company who becomes aware of an uncertainty in relation to the accuracy and truthfulness of the Player information provided shall immediately notify the MLRO and Transaction Monitoring Department, who will review the materials and determine whether further identification is required and/or so that it may be determined whether a report is to be sent to the relevant authorities.

If any substantial information of a Player changes, the update of the verification documents will be requested.

If a potential or existing Player either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the Company will not open a new account. After assessing the risks involved, it will consider closing any already existing account.

The Company does not accept Players from certain jurisdictions due to its own internal compliance reasons and also in order to comply with international sanctions’ requirements. These countries are listed in the Company’s Terms & Conditions.

The Company compares Player identification information with government or international provided lists of suspected terrorists and/or sanction lists of the United Nations, European Union, FATF and OFAC. If a Player appears on any list of suspected terrorists or otherwise sanctioned individuals the Company will take the appropriate steps to immediately freeze and/or close the account of the Player.

Politically Exposed Persons (PEPs) are broadly defined as individuals entrusted with prominent public functions, such as heads of state, members of parliaments, members of key government bodies and ambassadors, as well as members of their close families. PEPs are deemed to carry a higher risk of money laundering and so enhanced due diligence is required in respect of them, both at take on stage and on an ongoing basis.

3. Continuous transaction due diligence

The Company monitors account activity with a special attention to the background and purpose of any more complex or large transactions, and any transactions which are particularly likely, by their nature, to be related to money laundering.
Monitoring is conducted through the following methods:

a) Automatic monitoring
b) Manual review

All transactions are automatically monitored and a report is generated daily that show all transactions above USD 1,000 along with all the relevant details of the Players executing these transactions.

Parameters that signal possible money laundering include, but are not limited to:

a) Payments from/to high-risk geographic location without an apparent reason.
b) Incoming deposits almost immediately withdrawn without an apparent reason.
c) Transaction activity that is unexplained, unusually large or that shows unusual patterns or with no apparent specific purpose.
d) Customer provides unusual or suspicious identification documents that cannot be readily verified.
e) Sudden and unexpected activity on the account that was inactive for the longer period of time.
f) Frequent changes of payment methods or attempts to use any financial instruments related to other persons then the Player itself.

When an employee of the Company detects any activity that may be suspicious, he or she will notify the MLRO and Transaction Monitoring Department, which determines whether or not and how to further investigate the matter. This may include gathering additional information internally or from third-party sources, freezing the account and/or filing the report.

The Company does not accept cash or non-electronic payments from Players. Funds may be received from Players only by any of the following methods: credit card, debit card, electronic transfer, and any other compliant, legal, and properly traceable method approved by the respective regulators.

The Company will only transfer payments of winnings or refunds back to the same route from where the funds originated, where possible. Transfers of funds between Players accounts or any other third party transfers unrelated to the identified Player are strictly prohibited.

Records relating to the financial transactions shall be maintained in accordance with the data protection and retention requirements in the applicable jurisdiction of Union of Comoros.

4. Training Programs

The Company provides ongoing employee training under the leadership of the MLRO, Transaction Monitoring Department and senior management. The training occurs on at least an annual basis and is updated as necessary to reflect any new developments in the legal regulatory framework.

The training includes, at a minimum: (1) how to identify red flag alerts and signs of money laundering; (2) what to do once the risk is identified (including how, when and to whom to escalate unusual Player activity or other red flag alerts for analysis); (3) what employees’ roles are in the Company’s compliance efforts and how to perform them; (4) and the Company’s record retention policy.