elroyalecasino.com is operated by Wonder Play Company N.V.
AMLI Anti-Money-Laundering policy of elroyalecasino.com
Introduction: elroyalecasino.com is operated by Wonder Play Company N.V. having its office in Willemstad, Curacao. Company Registration number 162233.
Objective of the AML Policy: We seek to offer the highest security to all of our users and customers on elroyalecasino.com for that a three-step account verification is done in order to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into accord that depending on the nationality and origin, the way of payment and for withdrawal different safety measures must be taken.
elroyalecasino.com also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.
elroyalecasino.com is committed to high standards of anti-money laundering (AML) according to the EU guidelines, compliance and requires management & employees to enforce these standards in preventing the use of its services for money laundering purposes.
The AML program of elroyalecasino.com is designed to be compliant with :
EU : “Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering”
EU : “Regulation 2015/847 on information accompanying transfers of funds”
EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
BE : “Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash
Money Laundering is understood as:
Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.
In accordance with the AML legislation, elroyalecasino.com has appointed the “highest level” for the prevention of ML: The full management of Wonder Play Company N.V. are in charge.
Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) is in charge of the enforcement of the AML policy and procedures within the System.
The AMLCO is placed under the direct responsibility of the general Management:
Each major change of elroyalecasino.com AML policy is subject to be approved by the general management of Wonder Play Company N.V. and the Anti-money laundering compliance officer.
Step one verification:
Step one verification must be done by every user and customer to withdraw. Regardless of the choice of payment, the amount of payment, the amount of withdrawal, the choice of withdrawal and nationality of the user/customer step one verification must be done first. Step one verification is a document that must be filled out by the user/customer himself. Following information must be filled in: first name, second name, date of birth, country of usual residence, gender, and full address.
Step two verification:
Step two verification must be done by every user who deposits over 2000$ (two thousand USD) or withdraws over 2000$ (two thousand USD) or sends another user over 1000$ (one thousand USD) Until step two verification is done, the withdrawal, tip or deposit will be held. Step to verification will lead the user or customer to a subpage where he must send in his ID. The user/customer must make a picture of his ID. While a paperclip with a six-digit random generated number is next to his ID: Only an official ID may be used for ID verification, depending on the country the variety of accepted IDs may be different. There will also be an electronic check if the filled in Data from the step one verification is correct. The electronic check will check via two different databanks to insure the given information matches the filled document and the name from the ID: If the electronic test fails or is not possible the user/customer is required to send in a confirmation of his current residence. A certificate of registration by the government or a similar document is required.
Step three verification:
Step three verification must be done by every user who deposits over 5000$ (five thousand USD) or withdraws over 5000$ (five thousand USD) or sends another user over 3000$ (three thousand USD) Until step three verification is done, the withdrawal, tip or deposit will be held. For step 3 a user/customer will be asked for a source of wealth.
If a player deposits over a five thousand USD there is a process of understandings the source of wealth (SOW)
Examples of SOW are:
It is critical that the origin and legitimacy of that wealth are clearly understood. If this is not possible an employee may ask for an additional document or proof.
The account will be frozen if the same user deposits either this amount in one go or multiple transactions which amount to this. An email will be sent to them manually to go through the above and information on the website itself.
elroyalecasino.com also asks for a bank wire/credit card to further insure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.
The basic document will be accessible via the setting page on elroyalecasino.com. Every user has to fill out the following information:
The document will be saved and created by an AI, an employee may do additional checks if necessary based on the situation.
In order to deal with the different risks and different states of wealth in different regions elroyalecasino.com will categorize every nation into three different regions of risk.
For every nation from the region one the three-step verification is done as described earlier.
For every nation from the region two the three-step verification will be done at lower deposit, withdraw and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000$ (one thousand USD), withdrawing 1000$ (one thousand USD) or tipping another user/customer 500$(five hundred USD) Step three will be done after depositing 2500$ (two thousand five hundred USD), withdrawing 2500$ (two thousand five hundred USD) or tipping another user/customer 1000$ (one thousand USD). Also, users from a low risk region that change crypto currency in any other currency will be treated like user/customers from a medium risk region.
Regions of high risks will be banned. High risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.
In addition, an AI which is overseen by the AML compliance officer will look for any unusual behaviour and report it right away to an employee of elroyalecasino.com.
According to risk based factors and general experience the human employees will recheck all checks which were done before by the AI or other employees and may redo or do additional checks according to the situation.
In addition, a data Scientist supported by modern, electronic, analytic systems will look for unusual behaviour like: Depositing and withdrawing without longer Betting sessions. Attempts to use a different Bank account for Deposit and Withdraw, nationality changes, currency changes, behaviour and activity changes as well as checks, if an account is used by its original owner.
Also a User has to use the same method for Withdraw as he used for Deposit, for the amount of the initial Deposit to prevent any Money Laundering.
Enterprise-wide risk assessment
As part of its risk-based approach, elroyalecasino.com has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to elroyalecasino.com and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and transactions and other qualitative and emerging risks.
The identification of AML risk categories is based on elroyalecasino.com understanding of regulatory requirements, regulatory expectations and industry guidance. Additional safety measures are taken to take care of the additional risks the world wide web brings with it.
The EWRA is yearly reassessed.
AML-Compliance ensures that an “ongoing transaction monitoring” is conducted to detect transactions which are unusual or suspicious compared to the customer profile.
This transaction monitoring is conducted on two levels:
In its internal procedures, elroyalecasino.com describes in precise terms, for the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
Reports of atypical transactions are analyzed within the AML team in accordance with the precise methodology fully described in the internal procedures.
Depending on the result of this examination and on the basis of the information gathered, the AML team:
The AML rules, including minimum KYC standards will be translated into operational guidance or procedures that are available on the Intranet site of elroyalecasino.com.
Records of data obtained for the purpose of identification must be kept for at least ten years after the business relationship has ended.
Records of all transaction data must be kept for at least ten years following the carrying-out of the transactions or the end of the business relationship.
These data will be safe, encrypted and stored offline and online.
elroyalecasino.com human employees will make manual controls on a risk based approval for which they get special training.
The training and awareness program is reflected by its usage:
The content of this training program has to be established in accordance with the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML-specialist working for Wonder Play Company N.V. AML team.
Internal audit regularly establishes missions and reports about AML activities.
All data given by any user/customer will be kept secure, will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering data may be shared with the AML-authority of the affected state.
elroyalecasino.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC)