- Appointing a proper Money Laundering Compliance Officer (AMLCO) with adequate knowledge and seniority in the field and appropriate accountability to manage and monitor compliance oversight through the use of legitimate and appropriately fitting regulations, rules, legislation, and proper industry guidelines. Being one of the pivotal points of our operations, any and all AML measures are a direct responsibility of the Las Atlantis Casino management. An AMLCO is thus assigned to supervise and enforce such measures within the system. The AMLCO position implies direct subordination to the general management.
- Instituting and managing a money laundering and terrorist financing risk assessment through the use of a specifically established Risk-Based Approach (RBA). The scopes of AML Compliance Officer duties include overseeing an artificial intelligence algorithm designed to detect and report any suspicious activities performed by users. Within the general risk management strategy, such reports are subject to multiple further checks by the AMLCO and other employees if required.
- Utilizing the AI detection system reinforced by data science measures intended to identify unusual behavior patterns that may indicate fraudulent intent, including, but not limited to depositing and withdrawal without betting, using multiple bank accounts for transfers, and radical gaming pattern changes. Establishing the fact whether the same user is still in possession of the account is a part of such measures as well.
- Conducting an Enterprise-Wide Risk Assessment (EWRA) procedure to establish risks Las Atlantis Casino can be prone to, along with possible countermeasures. The results of the assessment were implemented in the process of creating this AML Policy, focusing on risk sources such as services, offers, users, transactions, third parties, legislation of different jurisdictions, and other emerging risks. EWRA is conducted annually to enable us to respond to risks arising from general World Wide Web activities, as well as industry requirements, expectations and guidance.
- Instituting and managing the identification, due diligence and if the occasion requires, proper Know Your Clients (KYC) procedure on any client that has been suspected of being risk-based. This may also include enhanced due diligence procedures on clients that have been presenting a higher risk, i.e. Politically Exposed Persons (PEP) etc. For more information – see our dedicated KYC page.
- Instituting and managing customer activity monitoring procedures and risk-based systems.
- Instituting various procedures for reporting any relevant suspicious client activity both internally and to the proper law enforcing authorities. All the employees involved with monetary operations are duly instructed as per how to detect and report suspicious transactions. The reports are contemplated by the AML team according to an established protocol. The results of such contemplation include a decision on whether the suspected account needs to be suspended or terminated and whether FIU needs to be informed on the issue, pursuant to the provisions of Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash.
- Managing and maintaining any relevant and applicable records for the minimum required time. We do not share any of the user’s data with third parties except for cases stated in our Privacy Policy. An AML authority of an affected state can request and obtain such data from us on the grounds of money laundering prevention by enforcing compliance to the law of such state.
- Implementing the proper awareness education on all relevant employees, assuring that all procedural requirements are met. The employees undergo regular training on AML, diversified to match the needs of every department involved. Conducting such training sessions is a direct responsibility of our AML officers. The internal network of Las Atlantis Casino contains the guidelines and instructions for every employee involved into the process of enforcing this Policy. The data received or otherwise emerging from AML activities shall be encrypted and stored for 10 years online and offline after the transactions or other actions took place. We conduct frequent internal audit to maintain the fulfillment of the provisions of this Policy.
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