Anti-Money Laundering Policy

Protecting the integrity of our gaming platform

Compliance Required

1. Policy Overview

Xemeaino Limited is committed to preventing money laundering and terrorist financing. We comply with all applicable anti-money laundering (AML) laws and regulations, including the EU Anti-Money Laundering Directives and Malta's Prevention of Money Laundering Act.

Our Commitment

  • • Implement robust customer due diligence procedures
  • • Monitor transactions for suspicious activity
  • • Report suspicious transactions to authorities
  • • Maintain comprehensive records
  • • Train staff on AML compliance

2. Know Your Customer (KYC) Requirements

Standard Verification (Required for all players)

Identity Documents
  • • Government-issued photo ID
  • • Passport or driver's license
  • • National identity card
Address Verification
  • • Utility bill (last 3 months)
  • • Bank statement
  • • Government correspondence

Enhanced Due Diligence (High-risk customers)

Additional verification may be required for:

  • • High-value transactions (€10,000+)
  • • Politically Exposed Persons (PEPs)
  • • Customers from high-risk jurisdictions
  • • Unusual transaction patterns
  • • Source of funds verification
  • • Source of wealth documentation

3. Transaction Monitoring

Automated Monitoring Systems

We use advanced automated systems to monitor all transactions for suspicious patterns:

  • • Large or unusual deposit amounts
  • • Rapid deposit and withdrawal cycles
  • • Minimal or no gaming activity
  • • Structuring transactions to avoid thresholds
  • • Multiple accounts from same source
  • • Transactions from high-risk countries
  • • Use of multiple payment methods
  • • Inconsistent betting patterns

Reporting Thresholds

  • • Single transactions: €15,000 or equivalent
  • • Cumulative transactions: €15,000 in 30 days
  • • Suspicious transactions: Any amount
  • • Cash transactions: €10,000 or equivalent

4. Suspicious Activity Indicators

Customer Behavior

  • • Reluctance to provide identification
  • • Providing false or inconsistent information
  • • Unusual nervousness or evasiveness
  • • Requesting anonymity or secrecy
  • • Multiple failed verification attempts
  • • Use of multiple identities

Transaction Patterns

  • • Deposits followed by immediate withdrawals
  • • Large deposits with minimal gaming
  • • Frequent small deposits to avoid detection
  • • Transactions inconsistent with profile
  • • Use of multiple payment methods
  • • Transactions from high-risk jurisdictions

5. Compliance Procedures

Account Freezing

We may freeze accounts pending investigation if suspicious activity is detected. Customers will be notified unless prohibited by law enforcement.

Suspicious Activity Reports (SARs)

We file SARs with the Financial Intelligence Analysis Unit (FIAU) Malta within required timeframes for all suspicious transactions.

Record Keeping

All customer identification documents and transaction records are maintained for a minimum of 5 years after account closure.

Customer Cooperation

Customers must cooperate with all AML procedures. Failure to provide requested documentation may result in account restrictions or closure.

6. Sanctions and Prohibited Persons

Sanctions Screening

We screen all customers against international sanctions lists including:

  • • UN Security Council Consolidated List
  • • EU Consolidated List
  • • OFAC Specially Designated Nationals List
  • • UK HM Treasury Consolidated List
  • • National sanctions lists

Prohibited Persons

We cannot provide services to individuals or entities on sanctions lists, or those acting on behalf of sanctioned parties. Accounts will be immediately frozen if sanctions matches are identified.

Compliance Contact

For AML compliance matters, questions, or to report suspicious activity:

  • Email: [email protected]
  • Phone: +356 2123 4567 (Compliance Department)
  • Address: Compliance Officer, 123 Gaming Street, St. Julian's, Malta
  • MLRO: John Smith, Certified Anti-Money Laundering Specialist