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AML POLICY

Cetrocon Software N.V.
E-Commerce Park Vredenberg,
Heelsumstraat 51, Curaçao

Anti Money Laundering (AML) Program and Compliance Procedures

Introduction : Cetrocon Software N.V., Reg No. 147338, having its registered address at E-Commerce Park Vredenberg, Heelsumstraat 51, Curaçao, licensed to conduct online gaming operations by the Government of Curacao under license 365/JAZ, sub-license GLH-OCCHKTW0707012018, Cetrocon Software N.V organizes gambling via the www.club7casino.com website (hereinafter the www.club7casino.com or Website). Under the license conditions www.club7casino.com is required to have in place adequate measures to prevent its systems from being used for the purposes of money laundering, terrorist financing or any other criminal activity.

Objective of the Policy: www.club7casino.com is fully committed to be constantly vigilant to prevent money laundering and combat the financing of terrorism in order to minimize and manage risks such as the risks to its reputation risk, legal risk and regulatory risk. It is also committed to its social duty to prevent serious crime and not to allow its systems to be abused in furtherance of these crimes.

www.club7casino.com will endeavor to keep itself updated with developments both at national and international level on any initiatives to prevent money laundering and the financing of terrorism. It commits itself to protect, at all times, the organization and its operations and safeguards its reputation and all from the threat of money laundering, the funding of terrorist and other criminal activities.

Obligations: In order to adhere to the requirements of the Prevention of Money Laundering Act, the regulations and any guidance notes www.club7casino.com shall as a minimum:

-Appoint one of its senior officers as the designated Money Laundering Reporting Officer (MLRO) whose responsibilities will include the duties required by the laws regulations and guidance notes.

-Take reasonable steps to establish the identity of any person for whom it is proposed to provide its service. For this purpose the process for the registration of Players provided for under the General Terms and Conditions provides for the due diligence process that must be carried out before the opening of a User Account. - keep at all times a secure online list of all registered Players.

-Any employee of the Company who becomes aware of an uncertainty in relation to the accuracy and truthfulness of the Player information provided shall immediately notify the AML Compliance Person, who will review the materials and determine whether further identification is required and or so that it may be determined whether a report is to be sent to the relevant authorities.

-Retain identification and transactional documentation as defined in the laws regulations and guidance notes.

-Provide initial and ongoing training to all relevant staff so that they are aware of their personal responsibilities and the procedures in respect of identifying Players, monitoring Player activity, record-keeping and reporting any unusual/suspicious transactions

-Ensure that this policy is developed and maintained in line with evolving statutory and regulatory obligation and advice from the relevant authorities.

-Examine with special attention, and to the extent possible, the background and purpose of any complex or large transactions and any transactions which are particularly likely, by their nature, to be related to money laundering or the funding of terrorism

-Cooperate with all relevant administrative, enforcement and judicial authorities in their endeavor to prevent and detect criminal activity.

-The Company will develop ongoing employee training under the leadership of the AML Compliance Person and senior management. The training will occur on at least an annual basis.

-It will be based on the Company’s size, its Player base, and its resources and be updated as necessary to reflect any new developments in the law.

The training will include, at a minimum:

  • How to identify red flags and signs of money laundering that arise during the course of the employees’ duties;
  • What to do once the risk is identified (including how, when and to whom to escalate unusual Player activity or other red flags for analysis;
  • What employees’ roles are in the Company’s compliance efforts and how to perform them;
  • The Company’s record retention policy
  • The disciplinary consequences for non-compliance with legislation

Moreover, www.club7casino.com shall:

-Not accept to open anonymous Accounts or Accounts in fictitious names such that the true beneficial owner is not known.

-Not accept cash from Players. Funds may be received from Players only by any of the following methods: credit cards, debit cards, electronic transfer, wire transfer cheques and any other method.

-Not register a Player who is under eighteen (18) years of age.

-Only register a single account in the name of a particular person: multi-account practices are strictly prohibited.

-Transfer payments of winnings or refunds back to the same route from where the funds originated, where possible.

-Not accept a wager unless a User Account has been established in the name of the Player and there are adequate funds in the Account to cover the amount of the wager.

-Not accept a wager unless the funds necessary to cover the amount of the wager are provided in an approved way.

-Not accept Players residing or playing from non-reputable jurisdictions.

-Documents to verify the identity information received will be requested from the Player if and when there is considered to be risk or uncertainty about the information provided and prior to any payment in excess of EUR 2,500 per occasion or when payments to the account are made in excess of EUR 2,500. These documents shall include, to the extent permitted under the relevant data protection regulations:

  • A copy of a valid identity card or passport;
  • Proof of address;

-Where it deems necessary, verify creditworthiness of the Player with third parties who previously provided any information on the Player.

-If it becomes aware that a person has provided false information when providing due diligence documents, not register such person. Where that person has already been registered, www.club7casino.com shall immediately cancel that person’s registration as a Player with the company


Curacao, 14/11/2018

Cetrocon Software N.V.
Management

Underage Gambling

You must be over the age of 18 or be the minimum age for gambling in your country of residence in order to register an account with us.

It is an offence for anyone under the age of 18 or the minimum age for gambling to attempt to place a bet or to register an account to attempt to place a bet.

We take our responsibilities in this regard very seriously and have sophisticated processes and software in place, which are used to carry out electronic age verification checks on all customers. We may also ask for additional support documentation such as a copy of Your passport and/or driving licence.

In the event that Cetrocon discovers You are under 18 years of age or under the legal age for gambling of the country in which you are resident, any deposited funds will be returned to you and no winnings will be paid out. Cetrocon will also report such attempts or activities to the Curacao Gambling Commissioner, who may refer the matter to your local prosecution authorities, parents, legal guardians or appropriate legal authorities.

Parental Controls

There are a number of third party applications that parents or guardians can use to monitor or restrict the use of their device's access to the Internet:

  1. Net Nanny filtering software protects children from inappropriate web content: www.netnanny.com.
  2. CYBERsitter filtering software allows parents to add their own sites to block: www.cybersitter.com.
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