Effective Date: 15 July 2025
Last Updated: 25 July 2025
1. Introduction
At Minibet Games, we are committed to preventing the misuse of our platform for money laundering, terrorist financing, and sanctions evasion. We uphold the highest standards of financial integrity and regulatory compliance while maintaining a seamless and secure player experience.
This policy outlines our internal systems, procedures, and responsibilities designed to detect and deter any financial or illicit crimes on our platform.
2. Policy Objectives
Minibet aims to:
- Detect and prevent the use of our platform for illegal financial activity.
- Verify the identity and risk profile of our users.
- Monitor and investigate suspicious transactions or behaviors.
- Fulfil any regulatory obligations in jurisdictions where we operate.
- Cooperate with relevant law enforcement or regulatory authorities.
3. Scope
This policy applies to:
- All users of the Minibet platform
- All employees and contractors handling payments or user data
- All financial transactions, deposits, and withdrawals made on Minibet
4. Definitions
- Money Laundering: The process of concealing the origin of criminally derived funds.
- Placement: Introduction of illicit funds into the system.
- Layering: Complex movements to obscure the origin.
- Integration: Reintroducing funds into the legitimate economy.
- Terrorist Financing: Providing or collecting funds with the intention of supporting terrorist activities.
- Suspicious Transaction: A transaction that appears inconsistent with a user’s profile or lacks clear economic purpose.
- Sanctions: Legal restrictions imposed by international authorities to prevent dealings with certain countries, individuals, and/or entities.
- PEP (Politically Exposed Person): a user who holds or has held prominent public office, requiring enhanced scrutiny.
5. Governance and Oversight
- Minibet designates a Compliance Officer (CO) responsible for AML/CTF implementation, investigation, and regulatory liaison.
- The CO oversees updates to this policy, risk evaluations, and suspicious activity reviews.
- The CO reports directly to senior management and maintains AML-related records and training logs.
6. Know Your Customer (KYC) & Customer Due Diligence (CDD)
We employ a risk-based approach to user verification. Depending on the user’s activity, risk level, and transaction volume, we may require to (verify):
- Government-issued photo ID (passport, ID card, driver’s license)
- Proof of address (utility bill, bank statement, etc.)
- Source of funds or wealth declaration (if applicable)
- Wallet address screening against blockchain forensics tools
- Sanctions list screening (e.g., OFAC, FATF, EU lists)
6.1 Enhanced Due Diligence (EDD)
For high-risk or suspicious users, additional verification may be required, including:
- Full legal name and permanent address
- National ID or tax identification number
- Proof of source of wealth/funds
- Additional background checks
- Ongoing transaction scrutiny
7. Geo-Restrictions & Sanctions Compliance
Minibet does NOT allow users from jurisdictions subject to international sanctions or legal prohibitions on gambling.
We employ the following to enforce compliance:
- IP-based geo-blocking
- Timezone consistency checks
- Sanctions list screening using internal tools or third party services
- Automatic blocking of users from prohibited regions
8. Transaction Monitoring
All user activity is monitored using a combination of automated and manual processes. This includes:
- Real-time analysis of deposits and withdrawals
- Pattern detection for unusual volumes, velocity, or behavior
- Threshold-based withdrawal checks triggering mandatory KYC
Red Flags Include (but are not limited to):
- Frequent large deposits/withdrawals with minimal gameplay
- Use of anonymizing services (e.g., mixers, privacy coins)
- Multiple accounts from same device/IP
- Attempts to fund via known sanctioned wallets or exchanges
9. Suspicious Transaction Reporting (STR)
Flagged transactions are initially reviewed by the Compliance Officer or appointed delegate within 48 hours. Logs are retained for a minimum of 5 years in accordance with regulatory expectations. Where required by law or licensing conditions, we may submit Suspicious Transaction Reports (STRs) to the relevant authority.
We reserve the right to suspend or permanently ban any user engaging in suspicious or prohibited activity.
10. Internal Training
All employees handling sensitive data or user accounts are given periodic AML/CTF training, including:
- How to identify red flags
- Steps for escalating concerns
- Confidentiality and data handling procedures
Training is refreshed annually or upon material changes to this policy or applicable law.
11. Vendor and Tool Risk Management
Minibet works with reputable third-party vendors (e.g. reputable wallet infrastructure). We:
- Review compliance capabilities of all critical service providers
- Monitor vendor risk on an ongoing basis
- Require vendors to adhere to strict data protection and AML standards
12. Prohibited Activities
Users are strictly prohibited from:
- Laundering proceeds of crime
- Funding from or transacting with sanctioned jurisdictions
- Using anonymizing services or privacy coins
- Transacting on behalf of third parties
- Circumventing platform security, geo-blocking, or KYC
Violation may result in account closure, fund freezing, and regulatory reporting.
13. Policy Review and Updates
This policy will be reviewed at least annually, or more frequently as needed based on regulatory developments or operational changes. All updates will be published on our website.
14. Contact
For questions or concerns about this AML policy, please contact our Compliance Team at: