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Anti-money Laundering Policy

Introduction

Rkgg maintains this Anti-Money Laundering (AML) Policy to prevent, detect, and report money laundering and the financing of terrorism in all operations conducted under its Curacao licensing framework. The policy applies to all employees, contractors, and affiliates of Rkgg, and to all products, services, and payment channels offered by Rkgg.

Scope and Regulatory Context

These controls govern customer onboarding, account maintenance, payment processing, and gaming transactions conducted through Rkgg. Rkgg adheres to applicable AML/CFT laws and licensing conditions, and maintains an independent Money Laundering Reporting Officer (MLRO) and compliance function to ensure ongoing compliance.

Risk-Based Approach

Rkgg conducts an annual risk assessment to identify inherent ML/TF risks. Relationships, products, geographies, and payment methods are categorized into risk levels. Resource allocation, due diligence, and continuous monitoring are proportional to the assessed risk.

Customer Due Diligence (CDD)

CDD requires identification, verification, and ongoing monitoring of customers. Verification is completed on onboarding and refreshed for higher-risk relationships.

  • Identity verification: Acceptable documents include a valid government-issued photo ID (passport, national ID, or driver’s license) with front and back copies. If photo ID is unavailable, a certified birth record accompanied by a current photo of the customer holding the birth certificate may be accepted.
  • Proof of address: Utility bill or bank statement in the customer’s name showing current residential address, issued within the last three months, uploaded or scanned in the customer area.
  • Source of funds and method-specific evidence: Documentation must establish funds provenance for each deposit method. Examples by method:
    • Card payments: copies of the registered card showing the cardholder name, first six and last four digits, and the cardholder's signature; CVV and middle digits must be redacted.
    • eWallets: screenshot of the wallet showing the linked email/account number and related identifiers.
    • Bank transfers: a recent bank statement (last three months) showing bank name, account number, IBAN, and BIC; all four corners visible.
    • Crypto: screenshots of the transaction and wallet profile showing account identifiers and associated email/user ID.
  • Ongoing verification: Verification requirements evolve with payment interfaces; KYC documentation may be updated to reflect method changes and new payment services.

Enhanced Due Diligence (EDD) and High-Risk Relationships

High-risk relationships or transactions trigger Enhanced Due Diligence. Rkgg maintains an EDD file including:

  • Comprehensive source of funds and wealth explanations;
  • Detailed business rationale and expected activity;
  • Increased ongoing monitoring with frequent reviews; and
  • Independent verification of key information where feasible.

Sanctions Screening and PEPs

Rkgg screens customers, beneficial owners, and payees against sanctions and Politically Exposed Persons (PEP) lists. Matches trigger immediate limitations on activity and escalation to the MLRO for action and reporting as required by law.

Ongoing Monitoring and Transaction Analysis

Rkgg applies automated and manual monitoring to identify unusual or suspicious activity. Monitoring accounts for customer risk profiles, transaction size, frequency, and payment channels. Any material deviation from the customer’s profile or any suspicion is escalated under established procedures.

Record Keeping and Data Retention

Rkgg retains comprehensive records to support AML/CTF investigations for not less than five years from the date of the last activity or account closure. Records include:

  • Customer identification and verification materials;
  • Transaction and payment records;
  • Risk assessments and due diligence documentation;
  • Internal and external SARs and related reports;
  • Training and policy review records.

Suspicious Activity Reporting (SARs) and Escalation

Any employee who knows or suspects money laundering or terrorist financing must report to the MLRO promptly, and in any event within 24 hours of becoming aware. The MLRO assesses the concern and, if warranted, files a SAR with the competent authority. Disclosure or tipping off is strictly prohibited and may constitute a criminal offence. No internal notes should be disclosed in a manner that would reveal an ongoing investigation.

Roles and Responsibilities

The MLRO operates independently to receive disclosures, assess risk, and coordinate reporting to authorities. Senior management bears ultimate responsibility for ensuring adequate resources and governance for AML/CTF compliance. The Compliance Officer supports the MLRO and oversees training, monitoring, and policy maintenance.

Training and Competence

Rkgg provides initial and ongoing training for all relevant staff addressing: CDD and EDD requirements, suspicious activity reporting, payment-method-specific due diligence, and internal escalation and record-keeping requirements.

  • CDD/EDD requirements, including high-risk clients and PEPs;
  • Suspicious activity identification and reporting;
  • Procedures for customer due diligence relevant to payment methods; and
  • Internal escalation and record-keeping obligations.

High-Risk Jurisdictions

Jurisdictions identified as high risk by FATF or the licensing authority require enhanced monitoring. Customers connected to such jurisdictions are subject to enhanced due diligence and ongoing monitoring until risk is satisfactorily mitigated or the relationship is terminated, as appropriate.

Vetting and Employment Screening

Rkgg conducts vetting of prospective employees, including identity verification, background checks, and references, through at least two independent sources to ensure suitability and to prevent misuse of AML controls.

Data Protection and Confidentiality

All customer information collected under this policy is treated as confidential, access is restricted to authorized personnel, and processing complies with applicable data protection laws and security standards.

Governance, Audit, and Policy Review

Rkgg maintains an AML/CTF governance framework including an MLRO and Compliance function. The policy is reviewed at least annually or upon significant regulatory change, with updates approved by senior management and communicated to staff.