El Royale Casino is devoted to preventing money laundering, implementing an anti-money laundering
infrastructure with specialized controls and systems designed specifically to facilitate the use of
our platform in anti-money laundering schemes.
Our El Royale Casino AML Policy is designed to establish our compliance with the required AML standards
and as such includes the following:
- Appointing a proper Money Laundering Compliance Officer (AMLCO) with adequate knowledge and
seniority in the field and appropriate accountability to manage and monitor compliance oversight
through the use of legitimate and appropriately fitting regulations, rules, legislation, and
proper industry guidelines. Being one of the pivotal points of our operations, any and all AML
measures are a direct responsibility of the El Royale Casino management. An AMLCO is thus assigned
to supervise and enforce such measures within the system. The AMLCO position implies direct
subordination to the general management.
- Instituting and managing a money laundering and terrorist financing risk assessment through the
use of a specifically established Risk-Based Approach (RBA). The scopes of AML Compliance
Officer duties include overseeing an artificial intelligence algorithm designed to detect and
report any suspicious activities performed by users. Within the general risk management
strategy, such reports are subject to multiple further checks by the AMLCO and other employees
- Utilizing the AI detection system reinforced by data science measures intended to identify
unusual behavior patterns that may indicate fraudulent intent, including, but not limited to
depositing and withdrawal without betting, using multiple bank accounts for transfers, and
radical gaming pattern changes. Establishing the fact whether the same user is still in
possession of the account is a part of such measures as well.
- Conducting an Enterprise-Wide Risk Assessment (EWRA) procedure to establish risks El Royale Casino
can be prone to, along with possible countermeasures. The results of the assessment were
implemented in the process of creating this AML Policy, focusing on risk sources such as
services, offers, users, transactions, third parties, legislation of different jurisdictions,
and other emerging risks. EWRA is conducted annually to enable us to respond to risks arising
from general World Wide Web activities, as well as industry requirements, expectations and
- Instituting and managing the identification, due diligence and if the occasion requires, proper
Know Your Clients (KYC) procedure on any client that has been suspected of being risk-based.
This may also include enhanced due diligence procedures on clients that have been presenting a
higher risk, i.e. Politically Exposed Persons (PEP) etc. For more information – see our
dedicated KYC page.
- Instituting and managing customer activity monitoring procedures and risk-based systems.
- Instituting various procedures for reporting any relevant suspicious client activity both
internally and to the proper law enforcing authorities. All the employees involved with monetary
operations are duly instructed as per how to detect and report suspicious transactions. The
reports are contemplated by the AML team according to an established protocol. The results of
such contemplation include a decision on whether the suspected account needs to be suspended or
terminated and whether FIU needs to be informed on the issue, pursuant to the provisions of Law
of 18 September 2017 on the prevention of money laundering limitation of the use of cash.
- Managing and maintaining any relevant and applicable records for the minimum required time. We
do not share any of the user’s data with third parties except for cases stated in our Privacy
Policy. An AML authority of an affected state can request and obtain such data from us on the
grounds of money laundering prevention by enforcing compliance to the law of such state.
- Implementing the proper awareness education on all relevant employees, assuring that all
procedural requirements are met. The employees undergo regular training on AML, diversified to
match the needs of every department involved. Conducting such training sessions is a direct
responsibility of our AML officers. The internal network of El Royale Casino contains the guidelines
and instructions for every employee involved into the process of enforcing this Policy. The data
received or otherwise emerging from AML activities shall be encrypted and stored for 10 years
online and offline after the transactions or other actions took place. We conduct frequent
internal audit to maintain the fulfillment of the provisions of this Policy.
El Royale Casino has implemented a risk-based Counter Financing of Terrorism (CFT) approaches and
procedure when facing any potential AML risk.
In addition, El Royale Casino has established specialized CFT internal controls, aimed to track and
conduct any relevant procedures towards CFT issues in a manner which overrules any other operating
task, business or strategy.
El Royale Casino is prohibited from making transactions with any companies, individuals and/or countries
that are listed on the prescribed sanctions lists.