Aml & Kyc Policy

1. Purpose and Scope

The Policy establishes Pgebet's obligations to prevent, detect and report money laundering and terrorist financing in relation to all services offered to customers and counterparties. It applies to all employees, officers, contractors, and agents acting on behalf of Pgebet, and to all activities conducted through our platform.

2. Governance and Compliance Oversight

Pgebet designates a Money Laundering Reporting Officer (MLRO) who operates with independence to receive disclosures, assess risks, and coordinate reporting to relevant authorities in accordance with applicable law. Senior management bears ultimate accountability for AML/CTF compliance and ensures adequate resources, training, and governance structures. A Compliance Committee reviews risk, controls, and escalating matters at least quarterly.

3. Customer Identification and KYC

  • Onboarding: We perform identity verification for all new customers prior to enabling withdrawals. Verification includes confirming name, date of birth, and residential address.
  • Documentation: Acceptable primary documents include a valid passport or national ID; acceptable secondary documents include a recent utility bill or bank statement showing the customer’s name and address.
  • Age and legal capacity: Applicants must be 18 years or older; age verification is conducted before enabling gaming and withdrawals.
  • Prohibition on multiple accounts: Each customer may hold a single account; duplication is prohibited and may result in closure of all linked accounts.
  • Data verification timelines: If electronic verification is inconclusive, documentary evidence may be requested within 72 hours; failure to provide may delay or suspend access.

4. Ongoing Monitoring and Risk Assessment

Pgebet applies a risk-based approach to ongoing monitoring. Customer risk profiles are established at onboarding and updated periodically based on activity, location, payment methods, and transaction patterns. High-risk indicators trigger enhanced monitoring and may require additional documentation or restrictions on activity.

5. Enhanced Due Diligence and High-Risk Jurisdictions

Customers presenting heightened risk such as those from FATF-designated high-risk jurisdictions or those with politically exposed person status are subject to Enhanced Due Diligence. EDD includes deeper verification of source of funds, ongoing source of wealth assessment, additional identity checks, and, where appropriate, reduced transaction limits or temporary account holds until risk is mitigated. The FATF list and equivalent local lists guide these determinations. Where risk remains unmitigated, access to services may be limited or terminated.

6. Source of Funds and Wealth

When risk signals are present or for high-risk customers, Pgebet requires a declaration of the source of funds and, where warranted, supporting evidence such as bank statements, salary documentation, or other credible documentation to confirm that funds originate from legitimate sources and align with the customer’s profile. Funds and transactions must be consistent with disclosed source of funds and declared wealth. Deposits of funds without a credible source may lead to hold or reversal of payments and potential sanctions.

7. Suspicious Activity Reporting and Disclosure

  • Grounds for knowledge or suspicion: Any employee who knows, suspects, or has reasonable grounds to suspect that a customer is engaged in money laundering or terrorist financing must report to the MLRO without delay.
  • Confidentiality and tipping off: All SARs and related disclosures are confidential. staff must not disclose or discuss AML concerns with the customer or any third party prior to or during investigation.
  • Escalation: The MLRO assesses and, where appropriate, files SARs with the relevant authorities. Delays or failures to report may incur criminal liability.

8. Records, Retention and Data Handling

Pgebet maintains a comprehensive audit trail to support law enforcement investigations and regulatory obligations. Records include customer identification documents, transaction histories, risk profiles, SARs, training records, and communications between the MLRO and management. Retention periods comply with applicable laws and regulator expectations, and records are secured to prevent unauthorized access, alteration, or destruction.

9. Training, Vetting and Internal Roles

  • Senior management and MLRO: Senior leadership is responsible for implementing the policy, allocating resources, and ensuring independent operation of AML/CTF controls.
  • Staff training: All staff receive initial AML/CTF training and ongoing refreshers focusing on customer due diligence, enhanced due diligence for high-risk clients (including PEPs), reporting suspicious activity, and internal escalation procedures.
  • Vetting of new employees: All new hires undergo identity verification and background checks, including at least two independent references, to confirm their suitability for roles involving access to payment systems and customer data.