Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy
1. Introduction
Pin Up is committed to maintaining the highest standards of security and integrity by implementing a robust Anti-Money Laundering (AML) and Know Your Customer (KYC) policy. These measures help prevent illegal financial activities and ensure compliance with global regulatory frameworks.
1.1 What is Money Laundering?
Money laundering involves concealing the origins of illegally acquired money, typically by means of transfers involving foreign banks or legitimate businesses. It allows criminals to disguise the true source of their income.
1.2 Our AML Strategy
Pin Up follows a strict AML protocol. This includes customer identification, transaction monitoring, record keeping, and mandatory reporting of suspicious behavior. We operate in full alignment with both local laws and international best practices.
2. Compliance Responsibilities
All employees are obligated to report any suspicion of money laundering or terrorist financing. These reports must be submitted promptly to our Risk Team and handled with strict confidentiality.
2.1 Operational Guidelines
- AML efforts are embedded across all departments.
- We carry out customer risk assessments during onboarding and throughout their activity.
- All suspicious cases are thoroughly documented and stored in accordance with legal retention requirements.
3. Risk-Based Approach
We evaluate the risk of money laundering for each customer and adjust our due diligence accordingly. Higher-risk individuals may be subject to Enhanced Due Diligence (EDD) processes to verify identity and source of funds.
4. Monitoring Transactions
We actively monitor customer behavior for unusual patterns or large transactions that may signal suspicious activity. Before processing withdrawals, we verify the legitimacy of deposit and betting activity.
5. Suspicious Activity Reporting
All employees must report any red flags immediately. Suspicious Activity Reports (SARs) are reviewed internally and escalated if necessary. Disclosure to the customer under investigation is strictly prohibited.
6. Role of the MLRO
The Money Laundering Reporting Officer (MLRO) is responsible for overseeing compliance, reviewing reports, and communicating with regulatory authorities. This officer operates independently and has access to required resources.
7. Staff Training
Pin Up ensures all relevant staff receive ongoing training on AML/KYC responsibilities. Training includes identifying suspicious behavior, following procedures, and understanding the legal implications of non-compliance.
8. KYC Requirements
We perform identity checks on all customers. Required documents include government-issued ID, proof of address, and in some cases, source of funds. Failure to provide valid documents may result in account suspension or closure.
9. High-Risk Jurisdictions
We follow FATF guidelines to identify high-risk countries. Customers from these jurisdictions may be denied access or required to undergo Enhanced Due Diligence.
10. Record Retention
All customer records, including verification documents and transaction logs, are stored securely for at least six years to comply with regulatory standards and support investigations if needed.
11. Legal Compliance & Offences
Employees are aware of the legal risks of failing to report or falsifying documents during AML processes. Any violation can result in legal consequences, including criminal prosecution.
12. Final Provisions
Pin Up reserves the right to modify this policy in accordance with regulatory changes and operational needs. Our goal is to foster a safe and transparent gaming environment for all users.