AML & KYC Policy

For Deposits and Withdrawals.

AML Anti-Money-Laundering Policy of jackpotter.com

jackpotter.com is operated by Bravo Entertainment and falls within the scope of AML obligations as outlined by Curacao legislation.

Objective of the AML Policy:

We strive to offer the highest security to all users and customers on jackpotter.com. To ensure this, a three-step account verification process is implemented to verify the identity of our customers. The goal is to confirm that the information provided by the user is accurate and that the payment methods used are not stolen or being used by someone else. This helps us create a framework to combat money laundering (ML). The specific measures taken may vary depending on the nationality, payment method, and withdrawal methods of the user.

jackpotter.com also implements reasonable measures to control and limit ML risks and dedicates the necessary resources to the task.

We are committed to adhering to high standards of anti-money laundering (AML) as set forth by the EU guidelines and regulatory compliance, and we require our management and employees to uphold these standards in order to prevent the use of our services for money laundering purposes.

The AML program of jackpotter.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 embargoes on certain goods and technology, including dual-use goods
• BE: “Law of 18 September 2017 on the prevention of money laundering and limitation of the use of cash”

Definition of Money Laundering:

Money laundering is understood as:

• The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or participation in such activity, for the purpose of concealing or disguising its illegal origin, or assisting anyone involved in such activity to evade legal consequences;
• The concealment or disguise of the true nature, source, location, disposition, movement, rights, or ownership of property, knowing that the property is derived from criminal activity;
• The acquisition, possession, or use of property, knowing at the time of receipt that the property was derived from criminal activity or assisting in such activity;
• Participation in, or aiding, abetting, facilitating, or consulting in the commission of these actions.

Money laundering is considered such even if the activities generating the property to be laundered took place in another Member State or in a third country.

Organization of the AML for jackpotter.com:

In accordance with the AML legislation, jackpotter.com has appointed the highest level of management to oversee the prevention of money laundering: The full management of Bravo Gaming.

Additionally, an AMLCO (Anti-Money Laundering Compliance Officer) is responsible for the enforcement of the AML policy and procedures within the system. The AMLCO reports directly to general management.

AML Policy Changes and Implementation Requirements:

Any significant changes to jackpotter.com’s AML policy must be approved by the general management of Bravo Gaming and the Anti-Money Laundering Compliance Officer.

Three-Step Verification:

Step One Verification:

Step one verification is mandatory for every user wishing to withdraw funds. This verification is required based on the payment method, withdrawal amount, and nationality of the user/customer. The user must fill out the following details:

• First name
• Second name
• Date of birth
• Country of usual residence
• Gender
• Address

Step Two Verification:

Step two verification is required for any user depositing over 2000 USDT or withdrawing over 2000 USDT. Until this step is completed, deposits, withdrawals, or tips will be held. The user must submit their ID, accompanied by a six-digit randomly generated number. Only official ID documents are accepted for verification. An electronic check will verify if the details from step one match the data in the ID. If the check fails or cannot be completed electronically, the user will need to submit a certificate of residence or another government-issued document confirming their address.

Customer Identification and Verification (KYC):

Customer identification is a critical element of both anti-money laundering (AML) and KYC (Know Your Customer) policies. This involves submitting:

• A copy of your passport, ID card, or driver’s license, shown alongside a handwritten note with six random generated numbers.
• A second picture of your face.
• The ID must be fully visible with all four corners in the same image, and the details must be clear and legible. You may blur sensitive information, such as your ID number, but the date of birth, nationality, gender, first and second names, and photo must remain visible.
• Additionally, proof of address is required via electronic verification, or a recent utility bill (less than 3 months old), or an official government document showing your address.

Risk Management:

To address the varying risks associated with different regions, jackpotter.com categorizes countries into three risk regions:

1. Region One: Low Risk
   Two-step verification is required for countries in this category.
2. Region Two: Medium Risk
   A three-step verification process is required for deposits, withdrawals, and tips over certain amounts. Step two is required after depositing or withdrawing 1000 USDT.
3. Region Three: High Risk
   High-risk regions are prohibited. These regions will be regularly updated based on changes in the global environment.

Additional Measures:

An AI system, overseen by the AML Compliance Officer, monitors unusual behavior and reports it immediately to an employee of jackpotter.com.

Users must use the same method for withdrawals as they did for their deposits to prevent money laundering.

Enterprise-Wide Risk Assessment (EWRA):

jackpotter.com conducts an AML Enterprise-wide Risk Assessment (EWRA) to identify and understand risks specific to its business model. This assessment includes risks associated with users, transactions, delivery channels, geographic locations, and other emerging risks. The EWRA is reassessed annually.

Ongoing Transaction Monitoring:

AML-Compliance ensures that ongoing transaction monitoring is conducted to detect any unusual or suspicious transactions compared to the customer profile. jackpotter.com works with trusted Crypto Payment Service Providers who implement effective AML policies to prevent suspicious deposits.

Reporting Suspicious Transactions:

jackpotter.com has internal procedures for reporting suspicious transactions. The AML team reviews these reports in accordance with established protocols, determining whether a report should be submitted to the Financial Intelligence Unit (FIU) or whether business relations with the customer should be terminated.

Procedures:

The AML rules, including KYC standards, are translated into operational guidance and procedures available to employees.

Training:

All employees involved in financial operations undergo mandatory AML training, which is regularly updated in accordance with the latest regulations.

Auditing:

Internal audits regularly assess the effectiveness of the AML procedures and report on activities.

Data Security:

All user/customer data is kept secure. Personal information will not be sold or shared unless required by law, or to prevent money laundering. jackpotter.com complies with the Data Protection Directive (Directive 95/46/EC).

Contact Us:

If you have any questions about our AML and KYC Policy, please contact us:

• By email: support@jackpotter.com
  If you have any complaints about our AML and KYC policy or the checks done on your account, please contact us:
• By email: support@jackpotter.com