AML & KYC POLICIES

Last Updated 19/04/2024

1. OVERVIEW

Winbit.io is operated by Trickless N.V. having its office at Zuikertuintjeweg Z/N, Curaçao and Company Registration number 160941.

We seek to offer the highest level of security to all of our users and customers on Winbit.io. Consequently, we have implemented a three-step account verification procedure in order to insure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into account that depending on the nationality and origin, the way of payment and for withdrawing different safety measurements must be taken.

Winbit.io also puts reasonable measures in place to control and limit money laundering risk, including dedicating the appropriate means.

Winbit.io is committed to the highest standards of anti-money laundering (AML) according to EU guidelines and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.

The AML program of Winbit.io is designed to be compliant with :

EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”

EU : “Regulation 2015/847 on information accompanying transfers of funds”

EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods

BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash”

2. DEFINITION OF MONEY-LAUNDERING

Laundering is understood as:

– The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, for the purpose of concealing or disguising the illegal origin of the property or of helping any person who is involved in the commission of such an activity to evade the legal consequences of that person’s or companies action;

– The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

– The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such an activity;

– Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

3. AML WEBSITE ORGANISATION

In accordance with the AML legislation, Winbit.io operates at the highest level for the prevention of ML, where the entire management are in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the Systems.

The AMLCO is placed under the direct responsibility of the general Management.

4. AML POLICY CHANGES AND IMPLEMENTATION REQUIREMENTS

Each major change of Winbit.io’s AML policy is subject to approval by the general management of Trickless N.V. and the Anti money laundering compliance officer.

5. THREE STEP VERIFICATION

Step one verification is mandatory for users upon withdrawal. Regarding the choice of payment-type, the amount of the payment, the amount of the withdrawal, the choice of withdraw and nationality of the user/customer step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. The following information must be filled in: first name, second name, date of birth, country of usual residence, gender and full address.

Step two verification is mandatory for any user who deposits over € 2000 (two thousand Euro) or withdraws over € 2000 (two thousand Euro). Until step two verification is complete the withdrawal, tip or deposit will be held. Step two verification will lead the user or customer to a sub-page requesting the player send in his ID. The user/customer will be required to take a picture of his ID. Only official ID may be used for ID verification, depending on the country the variety of accepted ID’s may be different. There will also be an electronic verification to determine whether the data fields from the step one verification have been correctly filled. The electronic verification will cross-verify two different data banks to ensure the information given matches the data on the data form and ID. If the electronic test fails or is not possible the user/customer will be required to send in a confirmation of his current place of residence. A utilities bill, certificate of registration by the government or a similar document is required.

Step three: Step three verification is required for every user who deposits over € 5000 (five thousand Euro) or withdraws over € 5000 (five thousand Euro) or sends another user over € 3000 (three thousand Euro) Until step three verification is complete, withdrawals, tips or deposits will not be processed. For step 3 a user/customer will be required to the source of income.

5.1 Customer Identification and verification (KYC)
The formal identification of clients is a vital element, both for the regulations relating to money laundering and for the KYC policy.
This identification rests on the following requirements:
– A copy of your passport, ID card or driving license, each shown alongside a handwritten note mentioning six random generated numbers. Also, a second picture with the face of the user/customer is required. The user/customer may blur out all surplus information, except for date of birth, nationality, gender, first name, second name and the picture.
Please note that all four corners of the ID have to be visible in the same image and all details must be clear and easy to read. We might ask for additional details and perform extra checks where necessary.
5.2 Proof of Address
Proof of address will be ascertained via various electronic verifications using two separate databases. If the electronic test fails, the user/customer has the option to provide proof manually.
We will require a recent utility bill sent to your registered address, issued within the last 3 months or an official government document proving your residence.
To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document are visible, and all text is clear and easy to read. (i.e. electricity bill, water bill, bank statement or any governmental post addressed to you.)
We reserve the right to request additional documentation where necessary.
5.3 Source of funds
If a player deposits over € 5000 (five thousand Euro) there will be a necessary process which requires the identification of the source of wealth (SOW) (i.e. business ownership, employment, inheritance, investment, family etc. )
It is critical that the origin and legitimacy of said wealth is clearly understood. If this is not possible an employee may ask for an additional documents or proof.
The account will be suspended if a user deposits this amount in one go or multiple transactions which amount to the same sum. In such a case the client will be contacted via email and we will provide assistance with the required verifications.
Winbit.io may also request a bank wire or credit card details to further insure the Identity of the user/customer and provide additional information about the financial situation of the user/customer.
5.3 Basic Verification Form
The basic document will be accessible via the settings page on Winbit.io and requires the following information: first name, second name, nationality, gender, date of birth.
The document will be parsed and saved via AI and employees may perform additional checks where necessary.

6 RISK MANAGEMENT

In order to deal with the different risks and different states of wealth in different regions around the globe, Winbit.io categorizes every nation into three different regions of risk.

Region 1 – Low Risk

For every nation from region one the three-step verification will be performed exaactly as described above.

Region 2 – Medium Risk

For every nation from region two the three-step verification will be done at lower deposit, withdraw and tip values. Step one will be performed as usual. Step two will be triggered after depositing € 1000 (one thousand Euro), withdrawing € 1000 (one thousand Euro) or tipping another user/customer € 500 (five hundred Euro). Step three will be triggered after depositing € 2500 (two thousand five hundred Euro), € 2500 (two thousand five hundred Euro) or tipping another user/customer € 1000 (one thousand Euro) . Also, users from a low risk region that change crypto currency into any other currency will be treated like users/customers from a medium risk region.

Region 3 – Medium Risk

Regions of high risks will be banned. High risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.

7. ADDITIONAL MEASURES

In addition, an AI system overseen by the AML compliance officer will look for any unusual behaviour and report it immediately to Winbit.io employees who will adopt a risk-based approach in verifying the reported information. Furthermore, a data Scientist supported by modern, electronic, analytic systems will look for unusual behaviour such as: depositing and withdrawing in the absence of lengthy betting sessions, attempting to use a different bank account for deposit and withdrawal, nationality changes, currency changes, behaviour and activity changes etc… and will verify that the account is being used by its original owner.

Users must use the same method for withdrawals that they used to deposit to prevent any Money Laundering.

8. ENTERPRISE-WIDE RISK-ASSESSMENT

As part of its risk-based approach, Winbit.io has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to Winbit.io and its business. The AML risk policy is determined after identifying and documenting the risks inherent to business lines such as the services the website offers, the Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.

The identification of AML risk categories is based on Winbit.io’s understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.

The EWRA is yearly reassessed.

9. ONGOING TRANSACTION MONITORING

AML compliance ensures that “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile. This transaction monitoring is conducted on two levels.

The first Line of Control – Winbit.io works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent the vast majority of suspicious deposits onto Winbit.io from taking place without proper execution of KYC procedures onto the potential customer.

The second Line of Control – Winbit.io makes its network aware so that any contact with the customer or player or authorized representative must give rise to the exercise of due diligence with regards to the transactions on the account concerned. In particular these include:

– Requests for the execution of financial transactions on the account;
– Requests in relation to means of payment or services on the account;

Also, the three-step verification with adjusted risk management should provide all necessary information about all customers of Winbit.io at all times.

Furthermore, all transactions must be overseen by employees over-watched by the AML compliance officer who is over-watched by the general management.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment, in relation to the knowledge of the customer (KYC), their financial behaviour and the transaction counterpart.

These checks will be done by an automated System, while an employee will cross check them for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of activities and origin of funds are therefore rapidly considered atypical (as they are not directly justifiable).

Any Winbit.io staff member must inform the AML division of any atypical transactions which they observe and cannot attribute to a lawful activity or source of income known of the customer.

The third Line of Control –

As a last line of defence against AML, Winbit.io will perform manual checks on all suspicious and higher risk users in order to fully prevent money laundering. If fraud or Money Laundering are discovered the authorities will be informed.

10. REPORTING OF SUSPICIOUS TRANSACTIONS

In its internal procedures, Winbit.io describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting. Reports of atypical transactions are analysed within the AML team in accordance with a precise methodology fully described in the internal procedures. Depending on the result of this examination and on the basis of the information gathered, the AML team:

– will decide whether it is necessary or not to send a report to the FIU, in accordance with the legal obligations provided in the Law of 18 September 2017;
– will decide whether or not it is necessary to terminate the business relations with the customer.

11. PROCEDURES

The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of Winbit.io.

12. RECORD KEEPING

Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended. Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.

These data will be safely encrypted and stored both off-line and on-line.

13. TRAINING

Winbit.io employees will manually effect controls with a risk-based approach for which they receive special training. The training and awareness program is reflected by its usage:

– A mandatory AML training program in accordance with the latest regulatory evolutions covering everything and anything pertaining to finances.
– Academic AML learning sessions for all new employees. The content of this training program is established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML Specialist working in the Trickless N.V. AML team.

14. AUDITS

Regular internal audits and reports concerning AML activities are diligently carried out by Winbit.io.

15. DATA-SECURITY

All data provided by users will be stored in a secure manner will not be sold or given to anyone else. We will only provide your data to third-parties where forced to do so by law, or to prevent money laundering (by sharing data with the appropriate authorities and jurisdiction).

Winbit.io scrupulously follows all guidelines and rules of the data protection directive (officially Directive 95/46/EC)

16. CONTACT

Should you require any further information regarding our AML & KYC policies, or if you have any complaints concerning the above policies, their interpretation or implementation, please contact our customer advisory services at [email protected]