Pin-Up Casino Bangladesh: Anti Money Laundering Policy

1. Exordium

1.1 Transmutations of Capital

Transmuting capital (TC) refers to the artifice whereby funds accrued through illicit endeavors, such as narcotics commerce or terroristic enterprises, are made to appear as deriving from benign origins. Malefactors orchestrate this illusion by obfuscating the provenance and altering the form or locale of these assets, thus diminishing their conspicuousness.

1.2 Countermeasures against Transmutations of Capital

The term 'countermeasures against transmutations of capital' (CTC) encapsulates the statutory mandates compelling financial entities and similarly obligated bodies to thwart, discern, and declare TC activities. An efficacious CTC schema necessitates a jurisdiction to:

  • Criminalize the transmutation of capital
  • Empower pertinent oversight bodies and law enforcement with investigative capabilities and necessary tools
  • Mandate that financial institutions ascertain client identities, install risk-tailored safeguards, maintain records, and report dubious dealings
  • Facilitate data exchange with other sovereignties as warranted

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2. Regulatory Framework

Personnel in the remote gaming sector must file a report upon:

  • Knowledge
  • Suspicion
  • Reasonable grounds for knowledge or suspicion of an individual’s involvement in TC or terror financing, inclusive of illicit expenditures

These prerequisites collectively form the basis for knowledge or suspicion. It is crucial that we demonstrate through evidential support that risk evaluations were conducted before initiating client engagements and that thorough client due diligence is performed to align customer transactions with their risk profiles.

The Merchant must demonstrate that continual risk-sensitive monitoring is performed, with all records preserved to reflect this, ensuring proper maintenance of risk profiles. This document outlines supplementary measures implemented for risk monitoring and circumstances necessitating a declaration of fund origins from clients posing elevated risks and potential for TC.

2.1 Specific Directives

The Merchant pledges adherence to compliance across all business facets, sanctioned by a licensed Curacao Gaming License, permitting operations of Chance Games on the international market via service lines.

3. Criminality, Disorder, and CTC Policies

CTC policies are founded on principles and practices:

  1. We develop systems and controls suited to our business needs, adhering to legal and regulatory demands
  2. We evaluate the CTC risks inherent in our current operations annually; thereafter, we adopt a flexible, effective, risk-sensitive, and cost-efficient approach
  3. We secure full commitment and accountability from senior management
  4. We periodically review the adequacy of our systems and controls
  5. We maintain necessary transaction records to support law enforcement efforts against TC and terror financing
  6. We ensure ongoing training for all pertinent employees
  7. We support the designated officer with the resources and authority needed for independent and objective operation

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4. Risk Administration

Our policies and procedures concerning risk assessment and management, as mandated by the Money Laundering Regulations 2007, involve several distinct steps to manage and mitigate identified money laundering and terror financing risks effectively:

  • Identify relevant risks
  • Develop and enforce policies and procedures to manage these risks
  • Continuously monitor and enhance the effectiveness of these controls
  • Document actions and rationales

This risk-focused strategy prioritizes efforts where they are most impactful, enjoying robust support from senior management and active employee cooperation. We have appraised our business’s exposure to TC risks, considering both the threat and its potential impact.

5. Dubious Activities

Herein, 'dubious activities' refer to suspicious transactions, atypical player profiles, and discrepancies in deposits among other indicators. Specific protocols enable us to identify players who necessitate a risk monitoring approach from our team and when enhanced due diligence checks on Player Profiles are imperative:

  • Passport or ID card
  • Utility bill
  • Bank statement
  • Additional proofs of identity

Enhanced Due Diligence Checks are tailored to players’ profiles and the associated risks they present. Only upon identifying certain criteria, individually or in combination, will we flag the customer(s) for risk monitoring. This includes verifying the customer’s employment, residential value, and ensuring the logical alignment of residential value with their spending patterns.

5.1 Dubious Activity Reports (DARs)

Within this structure, the imposition of Dubious Activity Reports (DARs) is mandatory. The Merchant obligates any employee to report to the Risk Team upon having grounds for knowledge or suspicion of an individual’s involvement in TC or terror financing. Failure to comply results in criminal prosecution.

DAR escalations should be conducted confidentially and discreetly, preferably in handwritten form to ensure utmost anonymity.

An employee must never disclose any AML concerns to the investigated individual or others, as such disclosure, also known as "tipping off," is strictly prohibited and incurs severe legal consequences.

Moreover, to maximize our protection, no comments should ever be made on an account indicating suspected TC, as a player can request full account notes/remarks at any time.

5.2 Operational Procedures

Reviewing players’ spending and gameplay to detect suspicious activity is standard before processing any withdrawals. This involves:

  • Assessing the customer’s deposit history to verify that no suspicious payments have been made
  • Evaluating the customer’s turnover to confirm legitimate casino play
  • Ensuring that refunds, when possible, are made to the original payment method used for deposits

5.3 Escalation Protocol

Adhering to AML policies and escalating any suspicious activity is vital for the company, protecting against financial losses and maintaining compliance across various jurisdictions. Even the slightest suspicion must be escalated to avoid criminal prosecution for non-compliance.

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6. Personnel

6.1 Executive Leadership

Senior management bears full responsibility and commitment to implementing this policy, acknowledging their personal liability for any offences committed through consent or neglect under the Regulations.

6.2 Money Laundering Reporting Officer (MLRO)

Designated MLRO, Nikos Lazos ([email protected]; +35780077001), is tasked with:

  • Reporting to senior management on AML and CTF activities
  • Receiving disclosures from employees under the Proceeds of Crime Act 2002 and the Terrorism Act 2000
  • Making appropriate external reports, if necessary

The MLRO operates independently, equipped with adequate resources to fulfill their duties.

6.3 Staff Training

All staff undergo training on their reporting obligations and are informed of the escalation procedures for any suspected incidents to the MLRO. Training includes guidance on client due diligence, particularly for high-risk clients, and the protocols for reporting suspicious activity to the designated officer.

7. High-Risk Jurisdictions

High-risk countries, as periodically identified by the Financial Action Task Force or the Gambling Commission, are subject to Enhanced Due Diligence (EDD). Currently, countries on the FATF list perceived as posing significant threats to the international financial system through ongoing and substantial money laundering or terrorist financing activities are:

  • Afghanistan
  • Algeria
  • Angola
  • Bosnia & Herzegovina
  • Ecuador
  • Guyana
  • Iraq
  • Lao PDR
  • Myanmar
  • Panama
  • Papua New Guinea
  • Syria
  • Uganda
  • Yemen
  • Iran
  • Democratic People’s Republic of North Korea

Players from these jurisdictions are categorically refused service.

8. Record Keeping

We maintain a comprehensive audit trail to assist in any financial investigation by law enforcement agencies. Our record-keeping policy covers various areas, including compliance monitoring, delegation of AML/CTF tasks, nominated officer reports to senior management, and customer identification and verification records.

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9. Legal Offences

Employees must be aware of their risks of committing offences under the Proceeds of Crime Act and the Terrorism Act, which include failure to report suspicious activity and wrongful disclosure that may prejudice an investigation.

10. Employee Vetting

We conduct thorough vetting procedures for new employees to ensure compliance with legal age and identification requirements, supported by at least two independent references and additional personal or background checks.

11. Protecting Our Assets from Internal and Criminal Misuse

We actively identify and protect our most valuable assets through integrated processes and controls, minimizing the risk of misuse. Our server equipment is managed with strict policies, including visitor management procedures, fire alarms, shredding of confidential documents, and security measures.

12. Compliance and Risk Committee

We have established a committee to oversee executive risk, comprising the MLRO, Compliance Officer, and a non-executive director, meeting quarterly or as needed.

13. Ensuring the Integrity of Business Partners

Our principles of business and professional ethics guide our selection of suppliers, assessing their financial strength, compliance with laws, commitment to corporate responsibility, and ability to deliver quality and value. All potential suppliers undergo a rigorous approval process to ensure alignment with our compliance obligations.

14. Responsibilities under the Proceeds of Crime Act

We are fully aware of and adhere to the policies and procedures required by the Proceeds of Crime Act 2002, ensuring compliance through detailed record-keeping.

15. Internal Record Keeping

Our key principles of knowing our customers, maintaining records, and reporting, ensure our adherence to laws and regulations. We keep records of all customer transactions and details for at least six years after their completion or termination.

16. Prevention of Collusion and Compliance with Data Protection

Our terms and conditions clearly state that cheating will not be tolerated, and any involved accounts will be closed. Data protection is rigorously enforced, with customer information securely managed and protected through comprehensive security policies.

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Know Your Customer (KYC) Policy

By agreeing to our terms, you authorize us to conduct necessary verification checks to confirm your identity and contact details. These checks may restrict withdrawals from your account during verification.

Inaccurate or incomplete information may lead to account termination or restrictions on service usage. If it is discovered that you were underage at the time of any transactions, your account will be closed, transactions voided, and funds returned, while any winnings will be forfeited.

Should your personal details change, it is your responsibility to inform us by contacting support.

Policy Objectives

The company may request verification in situations involving suspected fraud, doubts about document authenticity, violations of service conditions, or as deemed necessary. A standard set of identification data and documents, along with additional documentation, may be required.

Unverified or inappropriate documentation will result in non-approval, and the company reserves the right to decline service or terminate accounts in breach of the KYC policy.


Customers are subject to a due diligence process and record-keeping requirements. Anonymous or nominal accounts are not permitted and must be duly verified. Duplicate or multiple accounts identified as linked to the same individual will be subject to cancellation, with winnings forfeited and deposits returned or withheld as appropriate.

Politically Exposed Persons (PEPs) are monitored closely, with enhanced due diligence based on their gambling activities and location. Our questionnaires include specific inquiries to identify PEPs, and the company maintains the right to refuse service or terminate accounts for policy breaches.