Purpose and Scope
Ace365 maintains an anti money laundering and countering the financing of terrorism policy to prevent misuse of its wagering platforms for illicit purposes. This policy governs all Ace365 products including casino, live casino, sports betting, promotions and related services. It applies to all customers, employees, contractors, and affiliates acting on behalf of Ace365 and to all payment channels used for deposits and withdrawals.
Regulatory Framework
Ace365 complies with applicable anti money laundering and countering the financing of terrorism laws and regulations, including internationally recognised standards and any licensing requirements that apply to our operations. The policy also respects data protection and privacy requirements applicable in the jurisdictions where Ace365 operates, and it shall be implemented consistently with those obligations.
Governance and Oversight
The Chief Compliance Officer holds primary responsibility for the anti money laundering program. The CCO reports to the board on risk, control effectiveness, and regulatory changes. Ace365 maintains an AML compliance program that includes risk assessments, policy updates, internal controls, staff training, independent testing, and escalation procedures for identified deficiencies.
Customer Due Diligence and Know Your Customer
Ace365 conducts customer due diligence at onboarding and on an ongoing basis. At onboarding, we verify the identity of the customer before enabling any payout capability. Data collected includes full name, date of birth, residential address, contact details, and government issued identification. We assess the purpose and expected nature of the business relationship and identify beneficial ownership where applicable.
Methods of verification may include third party data sources, government issued documents, and corroborating information. Ace365 maintains a record of the verification results and supporting documentation. Ongoing due diligence is performed to confirm that customer information remains current and consistent with the activity of the account.
Enhanced Due Diligence and Risk Based Approach
Ace365 applies a risk based approach to due diligence. Customers are assigned risk levels low, medium or high based on factors including geography, source of funds, account activity, product usage, and information from adverse media. For high risk customers we implement enhanced due diligence which may involve additional documentation such as source of funds and source of wealth, closer transaction monitoring, more frequent reviews, and senior management approval for ongoing relationships.
Regular reviews of risk profiles are performed when the customer relationship evolves, regulatory changes occur, or new products are introduced. Where necessary, Ace365 requires additional controls before continuing the business relationship.
Ongoing Monitoring and Transaction Surveillance
Ace365 maintains ongoing monitoring of customer activity to identify suspicious or unusual patterns. Monitoring combines automated analytics with periodic manual review. Trigger events for enhanced review include large or unusual deposits or withdrawals, rapid movement of funds between accounts, complex payout structures, cross border transfers, or activity inconsistent with the customer profile.
All monitoring results are documented. If a transaction or activity raises suspicion of money laundering or terrorist financing, Ace365 promptly investigates and, where required by law, reports the matter to the appropriate authorities in accordance with statutory timelines.
Record Keeping and Data Retention
Ace365 retains customer identification data, verification documents, transaction records, and all AML related correspondence for a minimum of eight years from the date of last activity or termination of the relationship, whichever is later. Records are stored securely and retained in a manner that preserves their integrity and confidentiality for audit and regulatory purposes. Data processing complies with applicable privacy laws and the Ace365 privacy policy.
Sanctions, PEPs and Adverse Media
Ace365 screens customers against relevant sanctions lists and conducts ongoing screening for politically exposed persons and related associates. Enhanced due diligence is applied to PEPs and their family members or close associates. Ace365 also conducts adverse media checks as part of ongoing risk assessment and updates customer risk profiles accordingly.
Suspicious Activity Reporting and Cooperation with Authorities
When suspicious activity is identified, Ace365 promptly assesses the risk and, where required, files a report with the competent authority in accordance with applicable law. Ace365 cooperates fully with law enforcement and supervisory authorities and protects the confidentiality of any information disclosed as permitted by law. Ace365 does not disclose to customers or third parties that a report has been made, except as required by law.
Training and Awareness
All Ace365 personnel undergo AML training within a defined onboarding period and receive refresher training at least annually. Training covers identification of suspicious activity, process for escalation, data privacy obligations, and the roles and responsibilities of staff in maintaining a secure and compliant operation.
Operational Controls and Payment Handling
Ace365 requires verified payment methods for deposits and withdrawals. We do not support anonymous or unverified cash deposits. Payments are monitored for consistency with the customer profile and the declared source of funds. Large value transfers or unusual payment patterns trigger additional verification and review. Payments support documentation is retained as part of the customer file for audit purposes.
Policy Review, Audits and Compliance Reporting
This policy is reviewed at least annually or in response to regulatory changes. Material changes are approved by the board and communicated to relevant stakeholders. Ace365 conducts periodic internal and external audits to test the effectiveness of AML controls and implements corrective actions for any deficiencies identified during reviews.
Definitions
Money laundering means the process of concealing the true origin of illicitly obtained funds. Terrorist financing refers to facilitating or supporting the activities of individuals or organizations designated as terrorist or terrorist organizations. KYC refers to Know Your Customer procedures to verify identity and assess risk. CDD means customer due diligence. EDD means enhanced due diligence. PEP refers to a politically exposed person. Sanctions screening involves checking customers against relevant sanctions lists. Adverse media refers to negative information about a customer that could indicate higher risk.
Contact and Practical Information
For questions about this policy or to report concerns in relation to AML controls, contact Ace365 compliance at the designated compliance channel. All inquiries will be treated confidentially in accordance with applicable law and internal procedures.
Effective date: [Policy Effective Date]