PURPOSE
By implementing the presented Policy, the Company aims to achieve the following outcomes:
● processes and controls are put in place to mitigate the risk arising for the Company to be used, intentionally or unintentionally, for ML/TF purposes;
● potential risk customers are identified;
● the Company successfully fulfills the AML/CTF-related and other statutory obligations and effectively applies its Anti-Money Laundering Policies and Procedures, Underage Policy, Customer Interaction Policy and Responsible Gambling Policy.
GRANTING THE CUSTOMER STATUS
The customer means any natural person that formed a business relationship with the Company, by creating an online account at xsportsbet.com website. In that respect, Company's operational or reputational risk is generally based on that natural person's economic activity and/or source of wealth, which can be assessed from the information at the disposal upon the registration process.
The player can also be denied access to the website when it's deemed by the MLRO. Usually the denial or the end of the business relationship happens in the following instances:
● The player has connections to a jurisdiction that is of high risk to the company either by ML/CFT or business standards
● The customer provided fake documents in the CDD procedure
● The customer used fake credit/debit cards which resulted in chargeback requests from the payment provider
● There are indications that the customer is using multiple accounts to his/her advantage
● If the customer sends expired ID documents, or sends a document that is ripped or unclear in some manner
● The customer declines to send the requested CDD documents
● If it is determined upon registration that the customer is underage
● If the customer is a PEP, and the Board members do not allow him to continue the business relationship
KEY CUSTOMER ACCEPTANCE CONDITIONS
Upon initiating or assessing and before concluding or terminating business cooperation with the customer (assigning or suspending the player status) the Company conducts the following verifications:
Age verification
No person under the age of 18 is allowed to be accepted as our customer, to register and place bets at the xsportsbet.com website. However, if, after registering, there is reasonable doubt arising or strong evidence indicating the approved customer is underage, that user's customer status is suspended.
Geographic origin verification
The residence and place of birth of customers are taken into account upon the registration process, as these data might indicate substantial geographical risk arising from such natural persons. Potential customers originating from high-risk countries are considered as a threat by the Company and as such prohibited to be granted the status of our customers.
Customer risk verification
If, subsequent to the registration, there is a reasonable doubt pointing out some form of at-risk interaction with the player, namely:
- the player uses double accounts;
- the source of wagered funds may indicate an ML-issue;
- the player may have criminal records or adverse media
- the player is a PEP or a close relative thereof
- occupation and employment status
The Company, as per its legal obligations and internal corporate policies, helped by various CDD tools, reserves the right to refuse further service to such customers, as well as to freeze or suspend the customer's account until satisfactory feedback is obtained. Additionally, the customer type of play on the website is taken into consideration, as well.
Product/interface risk verification
The Company acknowledges that certain games offered may pose a higher/lower threat of ML/TF. xsportsbet.com offers a variety of online casino and online sports betting games to players, and categorizes the risk by the game itself. Besides the game, the Company acknowledges that the risk can arise from delivery channels risk or interface risk, such as products or services offered to non-face-to-face customers or online services.
Payment/Transaction Risk
The Company has in its general offer on the website a variety of payment methods that a customer can use at all times. The methods vary from credit/debit cards to e-wallets and vouchers. The multiple use of all payment methods can point to a higher risk behavior given that the customer is trying to hide the trace of these transactions.
