Purpose and Scope
Mmk121 maintains an AML/CTF program designed to prevent, detect, and report money laundering and terrorist financing within all areas of its operations. This policy applies to all customers, transactions, accounts, devices, and third‑party service providers engaged by Mmk121, and governs identity verification, funds provenance, and ongoing monitoring throughout the customer relationship.
Regulatory Basis
Mmk121 complies with applicable anti‑money laundering and counter‑terrorist financing laws and with regulatory guidance relevant to online gaming operators. The policy adopts a risk‑based approach aligned with prudent supervisory expectations and international risk‑mitigation standards.
Key Definitions
- Customer Due Diligence (CDD): verification of identity and assessment of risk before or during the course of a business relationship.
- Enhanced Due Diligence (EDD): additional measures for higher‑risk customers or transactions.
- Beneficial Ownership: identification of natural persons exercising ultimate ownership or control of a customer.
- Source of Funds: origin of the funds used in the customer’s transactions.
- Source of Wealth: overall financial means of the customer.
- Politically Exposed Person (PEP): a person who is or has been entrusted with prominent public functions.
- High‑risk Jurisdiction: countries or territories identified as high risk for ML/TF activity by applicable authorities.
Customer Identification and Verification (CDD)
Identity verification is mandatory before enabling financial transactions above a defined threshold. Required data include full legal name, date of birth, nationality, residential address, and government‑issued identification. Acceptable documents include passports, national identity cards, driving licenses, and utility bills for address verification. The minimum threshold for verification prior to processing is €2,000 or its equivalent in another currency; verification is completed promptly where possible.
Where identity cannot be established to the required standard, Mmk121 may suspend or decline any financial activity and may terminate the relationship in accordance with policy and law.
Enhanced Due Diligence (EDD)
EDD applies to higher‑risk customers or transactions, including but not limited to persons from high‑risk jurisdictions or those presenting complex ownership structures. EDD measures include verification of the source of funds and source of wealth, review of business ownership, and approval by senior compliance personnel. Additional documentation may be requested, and verification timelines may be extended accordingly.
Sanctions, PEPs and Screening
All customers are screened at onboarding and periodically thereafter against global sanctions and PEP databases. Any positive match triggers risk mitigation actions, including enhanced monitoring, possible transaction restrictions, and escalation to the designated compliance authority. Screening results are logged and retained as part of the customer file.
Ongoing Monitoring and Transaction Review
Mmk121 conducts ongoing, risk‑based monitoring of customer activity and transactional behavior. Triggers for heightened scrutiny include irregular deposit patterns, disproportionate fund flows, unusual velocity of transactions, use of third‑party payment instruments, or activity from high‑risk jurisdictions. Suspicious activity prompts manual review and escalation to the Money Laundering Reporting Officer (MLRO) for potential reporting to authorities and appropriate action.
Source of Funds and Source of Wealth
When required by risk assessment or regulatory triggers, customers must provide documentation describing the source of funds used in transactions and, for higher‑risk cases, the source of wealth. Acceptable documentation includes bank statements, payslips, tax documents, and other corroborating records. Mmk121 retains the right to request additional information to satisfy verification and risk concerns.
Record Keeping and Data Retention
All identification data, verification documents, transaction records, and SAR/UTR filings are securely stored and retained for not less than five (5) years from the date of the last activity or account closure, whichever occurs later. Records are made available to competent authorities upon lawful request and in accordance with applicable privacy and data protection laws.
Third‑Party Verification and Reliance
Where appropriate, Mmk121 may rely on approved third‑party verification providers under contract and audit trails. Reliance is subject to regulatory requirements, internal controls, and ongoing oversight to ensure continued integrity and independence of the verification process.
Client Obligations
By creating an account or using the platform, customers agree to provide complete and truthful information, undergo verification at Mmk121’s request, disclose the source of funds (and, where necessary, source of wealth), and promptly update information when changes occur. Failure to comply may result in restrictions, suspension, or termination of the account.
Account Termination and Freezing
Mmk121 reserves the right to terminate the business relationship or freeze an account where verification cannot be completed, information is false or misleading, the customer is identified on sanctions lists or as a PEP without adequate risk mitigation, or suspicious activity is detected. Frozen funds may be withheld and reported to authorities in accordance with law.
Confidentiality and No Tipping‑Off
All suspicious activity reports and internal AML communications are treated as confidential. Customers shall not be informed of ongoing investigations, reports, or corrective actions, except as required by law or regulation. Internal reviews, decisions, and communications with authorities are protected from disclosure to customers.
Governance, Roles and Responsibilities
The MLRO and Compliance Officer lead the AML/CTF program, with independent authority to file SARs and to escalate to senior management and law enforcement as required. Governance meetings occur at least quarterly and include escalation of risk findings and policy updates.
Training and Awareness
All staff receive ongoing AML/CTF training, covering CDD/EDD, suspicious activity indicators, reporting obligations, and escalation procedures. Training records are maintained and reviewed for adequacy and currency.
High‑Risk Jurisdictions
Customers from high‑risk jurisdictions are subjected to enhanced due diligence and ongoing monitoring. Transactions involving such jurisdictions are subject to additional controls, and in some cases may be restricted or blocked if risk cannot be adequately mitigated.
Escalation and Reporting
Any suspicion of money laundering or terrorist financing must be escalated promptly to the MLRO. The MLRO will determine whether a Suspicious Activity Report (SAR) or Unusual Transaction Report (UTR) should be filed with the competent authority. Tipping‑off is strictly prohibited, and no disclosures that could prejudice an investigation may be made to customers or third parties.
Policy Availability
A concise, publicly accessible version of this policy is available. The full policy is available upon legitimate request by regulators, partners, or institutional stakeholders through the Compliance Department.
Contact Information
Compliance Department: [email protected]