AML Policy of Betbits.com

Last Updated: 2025-05-07

1. Introduction

1.1. Betbits.com ("Website," "Platform") is operated by Unstoppable AC LTD (hereinafter "Betbits," "Company," "We," "Us," or "Our"), a company duly incorporated under the laws of Cyprus with the company number HE464758, and registered office at Griva Digeni, 1 RENANDA COMPLEX, BLOCK 1, Flat/Office 11, Agios Tychonas, 4532, Limassol, Cyprus.

1.2. Betbits operates under a gaming license issued by the relevant authority in Anjouan.

1.3. This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines the procedures and controls Betbits implements to prevent its services from being used for money laundering, terrorist financing, and other illicit financial activities. This policy is an integral part of our Terms of Service.

2. Objective of the AML Policy

2.1. Betbits is committed to maintaining the highest security standards for all users and customers on its platform. We implement robust AML/CTF measures to protect our users, our business, and the integrity of the financial system.

2.2. The primary objectives of this AML Policy are:

• To prevent Betbits’ services from being used for money laundering, terrorist financing, or any other criminal activity.
• To comply with all applicable AML/CTF laws and regulations in Anjouan, Cyprus (as applicable to corporate operations), and relevant international standards.
• To implement effective Know Your Customer (KYC) procedures and ongoing due diligence.
• To establish a risk-based approach to assess and mitigate ML/TF risks.
• To monitor and report suspicious activities to the relevant authorities.
• To provide ongoing training to our employees to ensure they understand and can fulfill their AML/CTF responsibilities.

3. Definition of Money Laundering and Terrorist Financing

3.1. Money Laundering (ML): The process of concealing the illicit origin of criminally derived property or funds. This typically involves three stages:

• Placement: Introducing illicit funds into the financial system.
• Layering: Conducting complex financial transactions to obscure the audit trail and sever the link with the original crime.
• Integration: Making the laundered funds appear legitimate.
• Money laundering includes activities such as:
  • The conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising its illicit origin.
  • The concealment or disguise of the true nature, source, location, disposition, movement, or ownership of property, knowing it is derived from criminal activity.
  • The acquisition, possession, or use of property, knowing at the time of receipt that it was derived from criminal activity.
  • Participation in, association to commit, attempts to commit, and aiding, abetting, facilitating, and counseling the commission of any of the aforementioned actions.

3.2. Terrorist Financing (TF): The provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in whole or in part, in order to carry out any of the acts which constitute terrorism, or to support terrorist acts, organizations, or individuals.

4. Organization of AML/CTF Compliance at Betbits

4.1. The Board of Directors of Unstoppable AC LTD holds ultimate responsibility for ensuring the Company's compliance with AML/CTF obligations.

4.2. Betbits has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for the day-to-day implementation, oversight, and management of this AML Policy and related procedures. The MLRO has sufficient independence and resources to perform these duties effectively.

4.3. The MLRO's responsibilities include, but are not limited to:

• Developing and maintaining AML/CTF policies and procedures.
• Ensuring appropriate KYC and due diligence measures are performed.
• Overseeing the monitoring of transactions and user activity.
• Investigating and reporting suspicious activities to the relevant authorities.
• Acting as the point of contact with law enforcement and regulatory bodies on AML/CTF matters.
• Ensuring regular AML/CTF training is provided to employees.
• Regularly reporting to senior management/Board of Directors on AML/CTF compliance.

5. AML Policy Changes and Implementation Requirements

5.1. This AML Policy is a living document and will be reviewed and updated regularly (at least annually or as needed) to reflect changes in regulations, risk assessments, and business operations.

5.2. Any significant changes to this AML Policy are subject to approval by the MLRO and senior management/Board of Directors of Unstoppable AC LTD.

6. Know Your Customer (KYC) and Due Diligence

Betbits will apply appropriate user due diligence and ongoing monitoring measures as required by law. We are committed to preventing users from engaging in illicit or otherwise unauthorized activity.

6.1. Customer Due Diligence (CDD)

• 6.1.1. Betbits has adopted a risk-based approach to CDD. All users are required to register an account and provide certain identification information as outlined in Section 4 (User Account Registration and Management) and Section 5 (Account Verification (KYC)) of our Terms of Service.
• 6.1.2. Identity and Age Verification:
  • At a minimum, before allowing full use of services including withdrawals, Betbits will collect and verify:
    • Full legal name.
    • Date of birth (to ensure the user is of legal age).
    • Residential address.
    • Email address.
    • Phone number.
    • For cryptocurrency transactions, wallet addresses used for deposits and withdrawals will be recorded.
  • Verification will be conducted using reliable, independent source documents, data, or information (e.g., government-issued photo ID, proof of address).
  • We may utilize third-party service providers for identity verification and screening against sanctions lists and Politically Exposed Persons (PEP) lists.
• 6.1.3. Understanding the Nature and Purpose: We aim to understand the intended nature and purpose of the user's relationship with Betbits to assess potential ML/TF risks.

6.2. Enhanced Due Diligence (EDD)

• 6.2.1. EDD measures will be applied to users or situations identified as presenting a higher risk. This may include, but is not limited to:
  • Users identified as Politically Exposed Persons (PEPs) or those associated with PEPs.
  • Users from or transacting with high-risk jurisdictions.
  • Users engaging in unusually large or complex transactions or patterns of transactions that appear to have no apparent economic or lawful purpose.
  • Users triggering specific red flags (see Section 8.2).
  • Any other situation deemed high-risk by the MLRO.
• 6.2.2. EDD measures may include:
  • Obtaining additional identification information (e.g., certified copies of documents).
  • Verifying the source of funds (SoF) and source of wealth (SoW). This may require bank statements, payslips, tax returns, or other relevant documentation.
  • More intensive ongoing monitoring of the business relationship and transactions.
  • Obtaining approval from senior management to commence or continue the business relationship.

6.3. Ongoing Monitoring

• 6.3.1. Betbits will conduct ongoing monitoring of user accounts and transactions to detect unusual or suspicious activity that may indicate ML/TF.
• 6.3.2. The extent of ongoing monitoring will be risk-sensitive.
• 6.3.3. We will ensure that KYC information and documents remain up-to-date and relevant by conducting periodic reviews, especially for high-risk users.

7. Acceptance Policy

7.1. Betbits will refuse to open an account, or may suspend or terminate an existing account, if:

• The user fails to provide satisfactory identification information and documentation required under our CDD/EDD procedures.
• The user provides false, misleading, or forged identification documents.
• The user attempts to use means to deceive their true location, particularly if they are from a Restricted Territory (as defined in our Terms of Service: United States, United Kingdom, Netherlands, France, Spain, Austria, Germany, Australia, and Comoros Island) or other high-risk/sanctioned jurisdictions.
• The user is identified as being subject to sanctions by major international bodies (e.g., UN, EU, US OFAC).
• The user is identified as a PEP and the associated risks cannot be adequately mitigated, or if SoF/SoW cannot be satisfactorily established.
• We have reasonable grounds to suspect that the user is involved in ML/TF or other criminal activities.
• The source of funds is known or suspected to originate from or be exchanged in restricted or high-risk jurisdictions without adequate explanation or proof of legitimacy.
• We are unable to form a reasonable belief that we know the true identity of the customer or beneficial owner.

7.2. Betbits reserves the right to refuse service, suspend, or close accounts at its sole discretion for any other reasons deemed necessary to comply with its AML/CTF obligations or to protect its business integrity.

8. Transaction Monitoring

Betbits employs a combination of automated and manual transaction monitoring systems to detect suspicious activities.

8.1. Key Monitoring Aspects:

• Screening for Sanctioned or Prohibited Jurisdictions/Parties: All users and their transactions are screened against relevant sanctions lists (e.g., OFAC, UN, EU). Transactions to/from identified high-risk wallet addresses or exchanges associated with prohibited jurisdictions may be blocked or subject to EDD.
• Blockchain Analytics: For all cryptocurrency transactions (deposits and withdrawals), Betbits will utilize blockchain analytics tools (e.g., Chainalysis or similar services) to:
  • Assess the risk profile of associated wallet addresses.
  • Identify links to illicit activities, sanctioned entities, mixers/tumblers, or darknet marketplaces.
  • Monitor transaction patterns for signs of structuring or layering.
• Unusual Activity Detection: Monitoring for transactions that are inconsistent with a user's known legitimate activities or financial profile, including unusual size, frequency, volume, or patterns.
• Anti-Mixing Measures: We will scrutinize transactions that appear to be structured to avoid reporting thresholds or to disguise the origin or destination of funds. Use of mixers or tumblers by users may lead to account suspension and EDD.
• Withdrawal Thresholds & KYC: While KYC is a continuous process, specific withdrawal thresholds (cumulative or individual) may trigger mandatory EDD or re-verification, depending on the account's risk profile and transactional history.
• Deposit and Gameplay Patterns: Monitoring for unusual deposit patterns not followed by commensurate gameplay, which could indicate attempts at money mixing.

8.2. Red Flag Indicators:

Betbits has identified several red flag indicators that may suggest potential ML/TF activity. These include, but are not limited to:

• Attempts to provide minimal, false, or inconsistent information during registration or KYC.
• Use of multiple accounts by the same individual without legitimate reason.
• Transactions that are unusual in size, frequency, or nature for the user.
• Deposits or withdrawals to/from cryptocurrency addresses known to be associated with illicit activity.
• Structuring of transactions to avoid scrutiny.
• Rapid deposit and withdrawal of funds with little to no gameplay.
• Reluctance to provide information regarding SoF/SoW when requested.
• Requests to make payments to third parties or use third-party payment methods.
• Use of VPNs or other tools to obscure location, especially from restricted territories.
• Alerts from blockchain analytics tools.
• Negative news or law enforcement information about the user.

8.3. When a red flag is triggered or suspicious activity is detected, the MLRO will be notified, and an investigation will be initiated. This may lead to account suspension, requests for EDD, and/or reporting to authorities.

9. Risk Assessment

9.1. Betbits adopts a risk-based approach (RBA) to AML/CTF compliance. This involves identifying, assessing, and understanding the ML/TF risks to which the Company is exposed, and implementing appropriate mitigation measures.

9.2. The risk assessment considers factors such as:

• User Risk: Including geographical location of users, user behavior, type of user (e.g., PEPs), and verification status.
• Product/Service Risk: Risks associated with online gaming, cryptocurrency transactions (volatility, anonymity potential), and payment methods.
• Geographical Risk: Risks associated with operating in or transacting with certain jurisdictions, including those known for high levels of corruption, weak AML/CTF regimes, or those subject to sanctions.
• Interface Risk: Risks associated with non-face-to-face customer onboarding and interactions.

9.3. The risk assessment will be reviewed and updated periodically (at least annually) or when significant events occur that may affect the Company's risk profile.

10. Record Keeping

10.1. Betbits will maintain records of all AML/CTF related information for a minimum period of five (5) years from the end of the business relationship with the user or from the date of the last transaction, or longer if required by applicable law.

10.2. These records will include:

• Copies of identification documents and verification data obtained through CDD/EDD.
• Details of all transactions conducted by users.
• Correspondence with users regarding their accounts and AML/CTF matters.
• Internal reports and records of any suspicious activity investigations.
• Records of AML/CTF training provided to employees.
• Reports made to regulatory authorities.

10.3. Records will be kept in a secure manner and will be made available to competent authorities upon legitimate request.

11. Reporting Suspicious Activity

11.1. Any employee who observes or becomes aware of any activity or transaction that they suspect may be related to ML/TF must promptly report their suspicions to the MLRO.

11.2. The MLRO will investigate all internal suspicious activity reports (SARs).

11.3. If, after investigation, the MLRO determines there are reasonable grounds to suspect ML/TF, a SAR will be filed with the relevant Financial Intelligence Unit (FIU) in Anjouan and/or other applicable authorities as required by law, without undue delay.

11.4. Betbits and its employees will not "tip off" any user that a SAR has been filed or that an investigation is underway, as this is prohibited by law.

11.5. Betbits will cooperate fully with law enforcement agencies and regulatory authorities in their investigations, subject to applicable legal constraints.

12. Employee Training

12.1. Betbits is committed to providing regular and comprehensive AML/CTF training to all relevant employees, including management, customer support, payments, and compliance staff.

12.2. Training will cover:

• AML/CTF laws and regulations applicable to Betbits.
• This AML Policy and internal procedures.
• The risks of ML/TF faced by the Company.
• Responsibilities of employees in combating ML/TF.
• How to identify and report suspicious activity (red flags).
• KYC and due diligence procedures.
• Record-keeping requirements.

12.3. New employees will receive AML/CTF training as part of their onboarding process. Refresher training will be provided periodically (at least annually) and when significant changes to policies, procedures, or regulations occur. Records of all training provided will be maintained.

13. Policy Review and Updates

13.1. This AML Policy will be reviewed by the MLRO at least annually, or more frequently if there are significant changes to the business, regulatory landscape, or identified risks.

13.2. Any updates to the policy will be approved by senior management/Board of Directors and communicated to relevant employees.

14. Contact for AML Queries

For any questions or concerns regarding this AML Policy, please contact our Support Team at: [email protected]