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Anti-Money Laundering

The Policy: 

Policy describes the requirements that need to be met with regards to the Customer Due Diligence procedure, as known KYC (Know Your Customer), for the purpose of preventing and reducing risks of money laundering and terrorist financing in dealing with customers: to provide understanding on how to conduct risk-based Customer Due Diligence (“CDD”) and Enhanced Due Diligence (“EDD”), how to help the Company to recognize the common red flags and triggers and take the appropriate action, know when and how to seek advice and report suspicions of money laundering or terrorist financing; avoid tipping-off anyone suspected of money laundering or terrorist financing.

Experience and Responsibility: 

Multi Pay N.V. adheres to strict codes of conduct to protect the company’s good standing, instill trust with the customers, comply with regulatory requirements and fulfil its ethical responsibility. The Company has lengthy experience in securing gaming businesses against criminal misuse and implementing wide ranging anti-fraud and anti-money laundering processes, procedures and extensive staff training programmes on this matter. 

Anti Money Laundering (AML)  and Counter Terrorist Financing (CTF): 

The Company has a responsibility to keep financial crime out of gambling. The possibility of gambling facilities being used by criminals to assist in ML or FT poses many risks for the Company, including criminal and regulatory sanctions for the Company or employees directly, civil action against the Company and damage to the reputation of the Company, leading to potential loss of business.

In relation to the prevention of money laundering (“ML”) and funding of terrorism (“FT”), reference should be made to the The Curacao Regulations requirement such as, risk assessment, written policies, procedures and controls, internal controls, Customer Due Diligence, record keeping and training. 

Multi Pay N.V. all customers activity monitored from registration, deposits, game play and withdrawals. During the monitoring period, at any stage of the customer life cycle the company can apply CDD or EDD to the customers, affiliates, providers and /or suppliers. 

Failure to complete the CDD and EDD process may lead to a hold or closing the business. 

Multi Pay N.V. it is everyone’s obligation (from directors to each employee) to report suspicions, not limited only to our customers, but also related to any person with whom we deal during the course of our regulated business. We are obliged to report prospective customers, agents etc .All suspicions regarding ML and TF must be reported to the MLRO but that suspicion must not be conveyed to the customer and further actions must await consents. The MLRO is then responsible for liaising with, submitting Suspicious Activity or Transaction Reports and seeking consents from the designated financial intelligence units. 

Multi Pay N.V. has also implemented KYC policy to assist in customer due diligence and ongoing monitoring process starting with customer acceptance policy. The company from time to time may request customer verification documents such as ID, PA, copf of financial documents, or documents to show source of the wealth or source of funds.  

Before being able to deposit and play on the site a customer needs to register an account and declare that they have read and accepted the Terms and Conditions and are over 18 years of age. The business is online and cash elements will not be accepted in order to mitigate risks associated with counterfeit monies. 

Customers coming from the restricted countries are not allowed to register. These countries will not be available to choose from the drop-down selection. This selection is based mostly but not limited to Statements and/or Declarations issued by the FATF.   

The Company will also keep a register of those customers that it identifies as high risk or politically exposed. Those accounts will be subject to greater scrutiny and frequency of checks.