The ML / FT Prevention and Control policies obey the need to guarantee the transparency and security of the operation, the trust of the player, compliance with the legal regulations on the matter and obviously, preventing, controlling and reporting situations or risks that expose the company to the effects associated with monies derived from criminal activities.


GENERAL POLICIES, in order to implement an asset laundering and terrorist financing prevention system, adopts the following policies:

•             It is the obligation of the officials of to have a straight, ethical and diligent behavior in complying with the regulations on prevention and control of money laundering and financing of terrorism that the law, the control entities and have established.

•             The PLAFT (Prevention and Control of Laundering Activities and Financing of Terrorism) manual is mandatory and must be fully known by all officials.

•             It is the policy of, to provide effective support and collaboration to the competent authorities.

•             All officials must put compliance with ethical standards and the prevention of risk of money laundering and financing of terrorism before the achievement of commercial goals

•             Any official who identifies and considers that an operation can be classified as unusual must immediately report it to the respective superior who will immediately inform the Compliance Officer.

•             All officials are obliged to follow internal policies and adopt behaviors that reveal strict compliance with the law and especially those that refer to money laundering and terrorist financing.


The policies are as follows:

1.            Not to establish any business relationship or of any other type, with natural or legal persons when there are reasonable doubts about the connection to the ML/FT and the consequent legality of the operations, legality or origin of its resources.

2.            Define the responsibilities, duties and authorities of the various management and control bodies of of the operator in relation to the PLAFT.

3.            Design a code of conduct for in accordance with the positive legislation that additionally establishes the corrective actions for non-compliance with the rules related to the PLAFT.

4.            Fully identify customers as established in this manual, prior to the delivery of the respective prize to the winner, withdrawal of funds from the gaming account represented in credits for participation or subscription of contract or equivalent document.

5.            Collaborate with the administration of justice, responding in a timely manner to the express requirements of the competent authorities and assisting them in the fight against ML/TF crimes, in accordance with current regulations

6.          Preservation of PLAFT documents with the due control measures that guarantee security, disposition of them for the relevant authorities and the other competent authorities.


7.      Maintain the confidentiality of the information that has been sent to the relevant authorities and the identity of the persons who have intervened in the operation classified as suspicious and that is the subject of a report to the relevant authorities or any other authorized authority, taking into account the provisions of the positive legislation.



Identifying customers


The identification of clients constitutes a mechanism for the prevention and control of ML / TF and will be carried out by the Establishment Administrator or the person in charge of the cash register; it will apply to the following people:

a)            Internet-operated game players who acquire credits for participation and / or withdraw funds from the gaming account represented in credits for participation by any form or means of payment authorized for an amount equal to or greater than USD $2,500 or its exchange in soles.

b)            Winners of localized and novel games and bets on sporting and similar events, except for games operated over the internet, whose prize is greater than 6,000.00, and winners of more than one monthly prize, whose sum exceeds 5,000 soles, current currency, must previously fill out the customer identification form


Those responsible for identifying clients must send the Compliance Officer weekly these physical formats with the supports of the transactions or payment of prizes in order for this information to be validated by the Compliance Officer and in accordance with the client registry.